Travel Wide Associated Sales (Phils.) v. Court of Appeals

Summary

Originally a breach of contract complaint for travel services, this case evolved into a significant procedural law precedent regarding the omnibus motion rule and special defenses. Decision Systems Corporation sued Travel Wide and TWA for failing to provide pre-paid hotel accommodations under a travel package deal. The defendants claimed they were mere agents of Tour Services, Inc. and thus not real parties-in-interest. The Regional Trial Court dismissed the case after a preliminary hearing, but the Court of Appeals reversed. The Supreme Court affirmed the reversal but clarified important procedural principles: that lack of cause of action is an exception to the omnibus motion rule and can be raised at any time, but preliminary hearings requiring evidence are improper for determining sufficiency of cause of action, which must appear on the face of the complaint. The Court also noted that defendants could still be liable as agents under Civil Code Article 1909 even if acting for disclosed principals.