G.R. No. 107824 July 5, 1996
SUPERCLEAN SERVICES CORPORATION, petitioner, vs. COURT OF APPEALS and HOME DEVELOPMENT MUTUAL FUND, respondents.

FACTS

Petitioner Superclean Services Corporation filed a complaint for Mandamus/Certiorari with Injunction against respondent Home Development Mutual Fund (HDMF). Petitioner alleged it was the lowest qualifying bidder for HDMF’s janitorial services contract for 1990, but HDMF unjustly refused to award the contract and scheduled a rebidding. The trial court issued a temporary restraining order against the rebidding and later allowed HDMF to hire month-to-month janitorial services.
By July 1991, the contract period for 1990 had lapsed. Petitioner moved to admit a “Supplemental Complaint,” arguing the delay rendered its prayer for mandamus moot. It sought to change its relief from compelling the award of the contract to claiming unrealized profits and damages. The trial court denied the motion, finding it would radically change the issues and prejudice HDMF. The Court of Appeals affirmed, ruling a supplemental pleading cannot substitute the original relief and that the original action was moot.

ISSUE

Whether the trial court gravely abused its discretion in denying the admission of petitioner’s Supplemental Complaint.

RULING

Yes. The Supreme Court reversed the Court of Appeals and ordered the admission of the pleading as an amendment to the original complaint. The legal logic proceeds as follows: First, the proper remedy under the circumstances was an amendment, not a supplemental pleading. Rule 10, §6 on supplemental pleadings covers subsequent facts in aid of the original cause of action or defense. Here, the supervening event (the lapse of the 1990 contract period) was cited not to aid the original demand for specific performance, but to justify a different relief—damages. This shift in prayer constitutes an amendment under Rule 10, §1, which is liberally allowed to serve the ends of justice.
Second, the amendment does not prejudice HDMF’s substantive rights. The core factual allegation—that HDMF unjustly refused to award the contract to the lowest bidder—remains unchanged. The new claim for damages is an alternative remedy flowing from the same alleged wrongful act. HDMF would have ample opportunity to file an amended answer and present its defense. Third, the original cause of action was not rendered moot, only the specific prayer for mandamus became impracticable. The situation is analogous to an illegal dismissal case where reinstatement is no longer feasible; the action survives for an alternative remedy like separation pay. Requiring a new complaint would exalt technicality over substance. The pleading, though mislabeled, should be treated as an amended complaint.