GR 200018; (April, 2015) (Digest)
G.R. No. 200018 , April 06, 2015
CITYSTATE SAVINGS BANK, INC., PETITIONER, VS. MAXIMIANO P. AGUINALDO, RESPONDENT.
FACTS
Maximiano P. Aguinaldo claimed ownership of a property in Parañaque City. He discovered that Rolando Mojica, Jr. had fraudulently obtained a title (TCT No. 142492) over the same property. Aguinaldo filed and won a case for the nullification of Mojica’s title. However, prior to this discovery, Mojica had mortgaged the property to Citystate Savings Bank, Inc. to secure a loan. Upon Mojica’s default, Citystate foreclosed the property, became the highest bidder at the auction, consolidated its title, and obtained TCT No. 151051. Aguinaldo then filed a Complaint for annulment of title against Citystate. During the pendency of this case, Citystate secured a writ of possession, resulting in Aguinaldo’s eviction and the demolition of his house, and subsequently sold the property to Syndica Phil. Corporation, which obtained TCT No. 178346. After the parties presented their evidence but before rebuttal, Aguinaldo filed a Motion to Admit Amended Complaint to implead Syndica as a co-defendant and to add claims for damages arising from his eviction and demolition. The Regional Trial Court (RTC) denied the motion, ruling that the amendments substantially altered the cause of action and would cause delay. The Court of Appeals (CA) reversed the RTC and ordered the admission of the amended complaint. Citystate filed the present petition.
ISSUE
Whether the Court of Appeals erred in reversing the RTC and ordering the admission of Aguinaldo’s Amended Complaint.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The Court held that amendments to pleadings are favored and should be liberally allowed to secure a just, speedy, and inexpensive disposition of every action. The amendment of the complaint did not alter the cause of action or theory of the case, which remained an action for annulment of title. The additional allegations and prayers (including the impleading of Syndica and claims for damages) were mere remedies necessitated by supervening events (the eviction, demolition, and sale to Syndica) that rendered the original relief inadequate. The amendment was necessary to afford complete relief, avoid multiplicity of suits, and resolve the controversy on its merits. A substantial alteration in the cause of action is not a bar to amendment under the 1997 Rules of Civil Procedure, provided it is not intended for delay. The Court found no intent to delay, as it was in Aguinaldo’s interest to have the case resolved promptly, especially after his eviction.