G.R. No. 157745 & G.R. No. 157955, September 26, 2006
GENALYN D. YOUNG, petitioner, vs. SPOUSES MANUEL SY and VICTORIA SY, respondents.

FACTS

Petitioner Genalyn D. Young filed a Complaint to nullify a Second Supplemental Extra-judicial Settlement, Mortgage, Foreclosure Sale, and Tax Declaration over an unregistered parcel of land. She alleged the extra-judicial partition executed by her mother, Lilia Dy Young, which adjudicated the property solely to Lilia, was void as it lacked court approval required since Genalyn was a minor at the time. This property was later mortgaged to respondent spouses Sy, foreclosed, and a Certificate of Sale was registered. Subsequently, petitioner filed a Motion to Admit Supplemental Complaint, invoking her right as a co-owner to legally redeem the property after respondents consolidated title in their name. The Regional Trial Court (RTC) denied the admission of this Supplemental Complaint.
In a separate but related procedural track, during the pendency of her petition challenging the denial of the supplemental complaint before the Court of Appeals (CA), the RTC proceeded with trial. Petitioner filed a last-minute Motion to Cancel a hearing due to a witness’s alleged indisposition. The RTC, sustaining respondents’ objection for violation of the three-day notice rule and the motion’s lack of merit, dismissed the main Complaint for non-suit.

ISSUE

The consolidated petitions raised two primary issues: (1) Whether the RTC committed grave abuse of discretion in denying the admission of the Supplemental Complaint; and (2) Whether the RTC committed grave abuse of discretion in dismissing the main Complaint for non-suit.

RULING

The Supreme Court denied both petitions. On the first issue, the Court held the RTC did not gravely abuse its discretion in denying the Supplemental Complaint. A supplemental complaint is proper only for facts occurring after the original pleading that do not alter the cause of action. Here, the original complaint sought the nullification of transactions based on the void partition. The supplemental complaint, seeking to exercise legal redemption, introduced a new and distinct cause of action premised on a different legal right (redemption under Article 1620 of the Civil Code) that could be pursued independently. Thus, its denial was proper.
On the second issue, the Court found no grave abuse of discretion in the RTC’s dismissal for non-suit. The power to dismiss a case for failure to prosecute is discretionary. The RTC’s order was based on petitioner’s pattern of seeking postponements and the specific last-minute motion that violated procedural rules and lacked substantiation (no medical certificate). The dismissal was not a patent refusal to exercise jurisdiction but a reasonable exercise of judicial discretion to prevent undue delay and prejudice to the respondents. Certiorari does not lie to correct mere errors of judgment absent a clear showing of capricious or whimsical exercise of power.