GR 154096; (August, 2008) (Digest)
G.R. No. 154096 ; August 22, 2008
IRENE MARCOS-ARANETA, DANIEL RUBIO, ORLANDO G. RESLIN, and JOSE G. RESLIN, petitioners, vs. COURT OF APPEALS, JULITA C. BENEDICTO, and FRANCISCA BENEDICTO-PAULINO, respondents.
FACTS
Petitioner Irene Marcos-Araneta filed two complaints before the Regional Trial Court (RTC) of Batac, Ilocos Norte against the late Roberto S. Benedicto and his associates. She alleged that shares of stock in two corporations were held by them under an express trust for her benefit, and she sought their reconveyance. The defendants moved to dismiss the complaints on grounds including improper venue, arguing Irene was not a resident of Ilocos Norte but of Makati City. The RTC initially dismissed the complaints, finding the actions were partly real and venue was improperly laid.
Pending reconsideration of the dismissal, Irene filed a motion to admit an amended complaint, adding three new plaintiffs who were residents of Ilocos Norte. The RTC granted the motion and admitted the amended complaint, reasoning that the inclusion of a resident co-plaintiff cured the venue defect. The respondents challenged this order via a certiorari petition before the Court of Appeals, which granted it. The CA annulled the RTC’s orders, holding that the amendment was not a matter of right after the original complaints had already been dismissed with finality, leaving no pending complaint to amend.
ISSUE
Whether the RTC acted with grave abuse of discretion in admitting the amended complaint after it had already dismissed the original complaints with finality.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the finality of judgments and the proper application of procedural rules on amendment. The RTC’s June 29, 2000 order dismissed the original complaints. Irene’s motion for reconsideration of this dismissal was denied in open court on August 25, 2000. This denial rendered the dismissal order final and executory, terminating the case and leaving no pending complaint before the court.
Consequently, when Irene filed her motion to admit an amended complaint, there was no longer any active pleading to amend. An amendment as a matter of right under Section 2, Rule 10 of the Rules of Court presupposes a pending complaint. Once a final order of dismissal is issued, the court loses jurisdiction over the case, save for the execution of the judgment. The RTC’s subsequent act of admitting an amended complaint was therefore a void act for lack of jurisdiction. The proper remedy for Irene after the final dismissal was to appeal the order or, if the dismissal was without prejudice, to refile a new complaint. The RTC’s contrary interpretation constituted grave abuse of discretion correctible by certiorari.