HEIRS OF MARCELINO PAGOBO, et al.; HEIRS OF HILARION PAGOBO, et al.; HEIRS OF ANTONIO PAGOBO, et al.; HEIRS OF MAXIMO PAGOBO, et al.; HEIRS OF DONATA PAGOBO WAGWAG, et al.; HEIRS OF AQUILINA PAGOBO, et al.; HEIRS OF JUANITO PAGOBO EYAS, et al.; HEIRS OF CATALINA PAGOBO, et al., petitioners,
vs.
THE COURT OF APPEALS, HON. RUMOLDO R. FERNANDEZ, (RTC BR. 54 LAPU-LAPU CITY in his capacity as Presiding Judge in CIVIL CASE NO. 2349-L) Judge of the Regional Trial Court, 7th Judicial Region Branch 54, Lapu-Lapu City; and Spouses GABRIEL and AIDA BANEZ, ANASTACIO PAGOBO, DEMETRIO PAGOBO and FELIX PAGOBO, respondents.
FACTS
On October 12, 1990, the petitioners (plaintiffs below) filed a complaint for “Declaration of Nullity of Documents, Reconveyances [sic] With Right of Legal Redemption, Damages & Attorney’s Fees” against the respondents (defendants below) before the Regional Trial Court (RTC) of Lapu-Lapu City, docketed as Civil Case No. 2349-L. The defendants filed their answer on December 7, 1990. On February 21, 1994, the plaintiffs filed a motion to admit an amended complaint, which was for “Partition, Declaration of Nullity of Documents, Cancellation of Transfer Certificate of Titles, [sic] Reconveyance With Right of Legal Redemption, Damages and Attorney’s Fees, and Other Reliefs.” The defendants opposed the motion. The RTC denied the motion to admit the amended complaint in an Order dated March 24, 1994, noting that the amended complaint re-included defendants who had been ordered dropped from the case in a previous order dated September 15, 1993, and citing the grounds in the defendants’ opposition. The plaintiffs’ motion for reconsideration and subsequent omnibus motion were also denied. The petitioners then filed a petition for certiorari with the Court of Appeals (CA), which affirmed the RTC’s order. The CA ruled that the amended complaint introduced additional causes of action (partition and cancellation of titles) and new issues, materially altering the grounds for relief from the original complaint for declaration of nullity and reconveyance. The petitioners then filed this petition for review on certiorari under Rule 45.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s denial of the petitioners’ motion to admit their amended complaint.
RULING
Yes. The Supreme Court GRANTED the petition, SET ASIDE the decision of the Court of Appeals and the Order of the RTC, and DIRECTED the RTC to admit the petitioners’ Amended Complaint.
The Court held that amendments to pleadings are favored and should be liberally allowed in the furtherance of justice, provided there is no showing that the motion to amend was intended to delay the action or that the amendment would cause injustice to the other party. The original and amended complaints were based on the same factual premises involving the same parcels of land and essentially sought the same relief: the recovery of ownership and possession of the subject lots. The amendments, which included a prayer for partition among the heirs and the cancellation of titles, did not introduce a new cause of action but merely amplified or supplemented the facts already alleged and the reliefs already sought. The cause of action remained the plaintiffs’ claim of ownership as heirs and the defendants’ alleged fraudulent deprivation thereof. The inclusion of the Register of Deeds as a party was also proper as he would be necessary to implement a judgment ordering cancellation of titles. The Court found no substantial prejudice to the defendants, as the core theory of the case remained unchanged, and any new matters could be addressed in an amended answer. The Court also held that the petition was properly filed under Rule 45, as it was a continuation of the appellate process over the original case.
