G.R. No. 250542 . October 10, 2022
HEIRS OF PIO TEJADA AND SOLEDAD TEJADA, REPRESENTED BY PIO DOMINGO TEJADA, PETITIONERS VS. GARRY B. HAY, IN SUBSTITUTION OF MYRNA L. HAY, REPRESENTED BY HIS ATTORNEY-IN-FACT GOMERCINDO LITONG, RESPONDENT.

FACTS

Myrna L. Hay filed a Complaint for Quieting of Title against the Heirs of Pio Tejada, claiming ownership over a parcel of land based on deeds of absolute sale from 1988 and 1997. The petitioners, initially acting without counsel, filed an Answer dated August 26, 2016, seeking the complaint’s dismissal on the ground that their father’s signature on the deeds was forged. After several postponements, pre-trial was conducted on June 28, 2017, and a Pre-Trial Order was issued. The initial trial date was also postponed multiple times. Subsequently, the RTC issued an Order dated June 27, 2018, referring the case to mediation.
On July 6, 2018, petitioners, now through counsel, filed a Motion for Leave to Admit Amended Answer with Counterclaim. They sought to clarify their admissions and denials with particularity and to assert compulsory counterclaims for the nullification of the deeds, declaration of their ownership, and an award of damages. They argued the amendment was proper as no responsive pleading had been filed, and the case had not yet gone to trial or preliminary conference, believing mediation was part of the pre-trial stage.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s denial of the petitioners’ Motion for Leave to Admit Amended Answer.

RULING

No. The Supreme Court denied the petition and affirmed the lower courts’ rulings. The Court emphasized that while amendments to pleadings are generally favored to determine cases on their real merits, such liberality is not absolute. The allowance of amendments after a responsive pleading has been filed or after pre-trial is subject to the court’s sound discretion. Here, a Pre-Trial Order had already been issued, conclusively establishing that the case had progressed beyond the pre-trial stage. The petitioners’ mistaken belief that mediation signified an ongoing pre-trial did not justify the amendment, as the rules clearly delineate pre-trial and mediation as distinct stages.
The legal logic rests on the principle that amendments sought after pre-trial must demonstrate compelling reasons, such as serving the ends of justice or preventing a miscarriage thereof, and must not be intended for delay. The Court found the proposed amendments were not indispensable. The core defense of forgery was already squarely raised in the original Answer. The added counterclaims for declaration of ownership and damages, while potentially compulsory, were not so integrally related to the main action for quieting of title that their omission would bar a future separate suit. The amendments essentially elaborated on existing defenses rather than introduced new ones necessary for a complete adjudication. Thus, the RTC did not commit grave abuse of discretion in its denial, as its decision was based on the procedural stage of the case and the non-essential nature of the amendments, not on a whimsical or capricious exercise of judgment.