GR 153777; (April, 2005) (Digest)
G.R. No. 153777 . April 15, 2005
Planters Development Bank, Petitioner, vs. LZK Holdings and Development Corporation, Respondent.
FACTS
Planters Development Bank (PDB) extended a ₱40 million loan to LZK Holdings and Development Corporation (LHDC), secured by a real estate mortgage over LHDC’s property. After LHDC allegedly defaulted, PDB extrajudicially foreclosed the mortgage and purchased the property at auction. LHDC filed a complaint with the Regional Trial Court (RTC) to annul the foreclosure and related loan documents, asserting the mortgage was void and it had not received the loan proceeds.
During pre-trial proceedings, LHDC filed a Motion for Leave to file a Supplemental Complaint. It alleged new events occurring after the original complaint was filed: that PDB had interfered with LHDC’s attempt to lease the building to a new tenant by imposing unreasonable conditions and had directly demanded rental payments from existing tenants. The RTC granted the motion and admitted the supplemental complaint. PDB filed a petition for certiorari with the Court of Appeals (CA), arguing the supplemental complaint introduced new causes of action and was prejudicial. The CA dismissed PDB’s petition, prompting this appeal.
ISSUE
Whether the Court of Appeals erred in upholding the RTC’s admission of LHDC’s supplemental complaint.
RULING
The Supreme Court denied the petition and affirmed the CA’s ruling. The admission of the supplemental complaint was proper under Section 6, Rule 10 of the Rules of Court. A supplemental complaint is meant to set forth transactions, occurrences, or events that have happened since the filing of the original pleading. The Court found that LHDC’s supplemental pleading precisely alleged such subsequent events—PDB’s post-complaint interference with lease negotiations and tenant relations—which were germane to the existing controversy over the foreclosure and the parties’ rights to the property and its income.
The legal logic is that supplemental pleadings are allowed to promote the complete adjudication of a dispute in a single proceeding, avoiding multiplicity of suits. The core issues from the original complaint remained unchanged; the supplemental allegations merely expanded the factual basis related to the same core dispute. The Court noted no prejudice to PDB, as it retained the right to file a supplemental answer. The ruling emphasizes that procedural rules should facilitate the just, speedy, and inexpensive determination of every action, and the trial court acted within its discretion to admit the pleading to serve the ends of justice.