G.R. No. 131175 ; August 28, 2001
SPOUSES JOVITO VALENZUELA and NORMA VALENZUELA, SPOUSES ALFREDO QUIAZON and BELLA GONZALES QUIAZON, SPOUSES EDUARDO DE GUZMAN and JULIETA DE GUZMAN, DE GUZMAN DEVELOPMENT CORPORATION, SKYFREIGHT BROKERAGE, INC., ATTY. ROMULO R. BOBADILA and WEB-HEGG CONSTRUCTION RESOURCES, INCORPORATED, petitioners, vs. HONORABLE COURT OF APPEALS and SPOUSES MANUEL T. DE GUIA and LETICIA MARIANO DE GUIA and the REGISTER OF DEEDS OF PARAÑAQUE CITY, METRO MANILA, respondents.

FACTS

On September 10, 1981, respondents Spouses Manuel and Leticia De Guia filed a complaint for specific performance and damages (Civil Case No. PQ-9412-P) against petitioners Spouses Jovito and Norma Valenzuela, praying that the Valenzuelas be ordered to execute a deed of sale for two parcels of land subject of a contract to sell. On September 16, 1981, upon discovering the properties had been sold to petitioners Spouses Alfredo and Bella Quiazon, respondents filed a separate complaint for annulment of sale, cancellation of title, and damages (Civil Case No. PQ-9432-P) against the Valenzuelas, the Quiazons, and the Register of Deeds. Respondents later sought to amend this second complaint multiple times to implead additional defendants, including Webb-Hegg Construction Resources, Inc., Gerardo Villacorta, Spouses De Guzman, De Guzman Development Corporation, Skyfreight Brokerage, Inc., and Atty. Romeo Bobadilla. The trial court denied the motion to admit a third amended complaint and later dismissed Civil Case No. PQ-9432-P. This dismissal was affirmed by the Court of Appeals and the Supreme Court. Subsequently, on March 18, 1996, respondents filed a motion to admit an amended complaint in the original case (Civil Case No. PQ-9412-P). The Regional Trial Court (RTC) of Pasay City, Branch 231, denied this motion. The Court of Appeals reversed the RTC and ordered the admission of the amended complaint. Petitioners then filed this petition, arguing the amendment should not be allowed as it would radically change the cause of action and theory of the case.

ISSUE

Whether the amendment of the complaint in Civil Case No. PQ-9412-P should be allowed despite being filed after a lapse of fifteen years from the filing of the original complaint.

RULING

Yes, the amendment of the complaint should be allowed. The Supreme Court affirmed the decision of the Court of Appeals. The Court emphasized that procedural rules, such as those governing amendments of pleadings under Rule 10 of the 1997 Rules of Civil Procedure, are designed to secure a just, speedy, and inexpensive disposition of every action. Procedural laws are retroactive and no one has a vested right in them. The 1997 Rules, which liberalized the policy on amendments, apply to pending actions. The amendment sought by respondents, which essentially integrated the causes of action from the dismissed Civil Case No. PQ-9432-P into the pending Civil Case No. PQ-9412-P, was substantial. However, the Court found that the amendment was not made with intent to delay but to avoid multiplicity of suits and to determine the actual merits of the controversy speedily. The Court held that the rules of procedure should not be perverted into engines of injustice and that the amendment would serve the ends of justice by allowing a complete adjudication of the rights of all parties involved. Therefore, the RTC was ordered to admit the amended complaint.