G.R. No. L-14243; June 30, 1961
JOSE L. UY, plaintiff-appellee, vs. OSCAR L. UY, defendant-appellant.

FACTS

Plaintiff Jose L. Uy and defendant Oscar L. Uy, brothers, were co-owners of Hacienda Fe. On September 6, 1948, Jose sold his undivided share to Oscar for P100,000, with P20,000 paid upfront and the P80,000 balance secured by a second mortgage on half the property. Oscar later paid P30,000 on account. On December 11, 1948, they executed an “Amendment of Terms,” stipulating that the remaining P50,000 balance would be paid within one year with 12% annual interest. Jose filed a complaint in 1955, alleging Oscar failed to pay P40,000 of the balance. After procedural motions, Jose filed an amended complaint, eliminating other defendants and specifically alleging the 12% interest stipulation from the 1948 amendatory agreement.
The trial court granted leave to file the amended complaint over Oscar’s opposition. Oscar filed a petition for certiorari with the Supreme Court challenging this order, which was denied. The case proceeded, and a commissioner was appointed to examine the accounts. The commissioner’s report, based on the 12% interest from the 1948 amendment, indicated Oscar owed P51,384.34. The trial court rendered judgment for Jose based on this report.

ISSUE

The primary issue is whether the trial court committed reversible error in: (1) granting leave to file the amended complaint, and (2) admitting the commissioner’s report (Schedule “B”) which computed the obligation based on the 12% interest rate stipulated in the December 11, 1948 amendatory agreement.

RULING

The Supreme Court affirmed the trial court’s judgment. On the first error, the Court held that the trial court did not abuse its discretion in admitting the amended complaint. Amendments to pleadings are freely allowed under the Rules of Court to ensure that the real matters in dispute are presented. The amended complaint did not substantially alter the cause of action or theory of the case, which remained an action for recovery of a sum of money based on an obligation. It merely supplemented the allegation by incorporating the specific amendatory agreement and its 12% interest stipulation, and eliminated parties no longer necessary. There was no showing the amendment was intended to delay. The Court’s prior denial of Oscar’s certiorari petition against the amendment order was conclusive on this point.
On the second error, the admission of the commissioner’s report (Schedule “B”) was proper. Oscar’s objection was not to the mathematical accuracy of the computation but to the very basis of the computation—the December 11, 1948 agreement. Since the Court upheld the validity of the amended complaint which integrated that agreement, the commissioner correctly used it as the basis for calculating the outstanding obligation with 12% interest. Therefore, the trial court committed no error in relying on the commissioner’s findings. The judgment ordering Oscar to pay Jose P51,384.34 with 12% interest from April 1, 1956, was in accordance with law and the evidence.