G.R. No. 80001 February 27, 1989
CARLOS LEOBRERA, petitioner, vs. THE COURT OF APPEALS and BANK OF THE PHILIPPINE ISLANDS, respondents.

FACTS

Petitioner Carlos Leobrera obtained an P800,000 credit facility from respondent Bank of the Philippine Islands (BPI) in 1980, secured by two real estate mortgages. This facility was later converted into a revolving promissory note line. Separately, in 1985, Leobrera obtained a distinct three-year term loan of P500,000 from BPI, secured by a third real estate mortgage. When negotiations for renewing the matured notes for the first loan failed, BPI demanded payment and prepared to foreclose the corresponding mortgages.
To prevent this, Leobrera filed a complaint for damages with a prayer for a writ of preliminary injunction (Civil Case No. 15644). The trial court issued a preliminary injunction restraining foreclosure on the first loan’s securities. Subsequently, BPI accelerated the maturity of the separate three-year term loan due to an alleged payment default and threatened to foreclose its securing mortgage. Leobrera then filed a “Motion to File Supplemental Complaint” to enjoin this new foreclosure threat, which the trial court granted, issuing a restraining order.

ISSUE

Whether the Court of Appeals erred in ruling that the trial court abused its discretion in admitting the supplemental complaint.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The trial court improperly admitted the supplemental complaint. Under Section 6, Rule 10 of the Rules of Court, a supplemental complaint sets forth transactions, occurrences, or events happening after the original pleading that relate to the cause of action therein. The supplemental complaint here involved a cause of action distinct from the original.
The original complaint concerned the P800,000 credit facility and its alleged improper acceleration and foreclosure, stemming from a 1980 amicable settlement. In contrast, the supplemental complaint addressed the separate P500,000 term loan, its alleged acceleration due to a different default in 1987, and a new threat to foreclose a different mortgage. The factual bases and the questioned bank actions were independent. The supplemental claim did not arise from the same transaction or series of transactions pleaded originally but constituted a new and distinct matter. Therefore, the Court of Appeals correctly held that the supplemental complaint was improperly admitted, as it introduced an unrelated cause of action that could not be joined via a supplemental pleading. The temporary restraining order was lifted.