GR L 5313; (December, 1909) (Digest)
G.R. No. L-5313
JUANA ESPIRITU, plaintiff, vs. A. S. CROSSFIELD, judge of the Court of First Instance of Manila, and VICENTE GUASH, administrator of the estate of Jose Jimenez y Mijares, defendants.
December 10, 1909
FACTS:
Vicente Guash, as administrator of Jose Jimenez y Mijares, initiated a civil action in the Court of First Instance (CFI) against Juana Espiritu to recover certain personal property. During the proceedings, the property was taken from Espiritu’s possession and delivered to Guash. The CFI ruled in favor of Guash.
Espiritu appealed to the Supreme Court. The Supreme Court reversed the CFI’s decision, absolved Espiritu, and dismissed the action, finding that the lower court had failed to make the necessary factual findings or that the pleadings lacked required allegations under Section 712 of the Code of Civil Procedure. This judgment by the Supreme Court was final and was remanded to the CFI for execution.
Despite the final judgment by the Supreme Court dismissing the original action, Guash, with the CFI’s permission, filed an amended complaint in the same original case, attempting to revive the cause of action.
Consequently, Juana Espiritu filed the present original action for mandamus and prohibition in the Supreme Court against Judge A. S. Crossfield (of the CFI) and Guash. She prayed for: (1) a writ of mandamus compelling Judge Crossfield to issue an execution for the return of the personal property to her, and (2) a writ of prohibition to stop Judge Crossfield from proceeding with Guash’s amended complaint.
ISSUE:
Can pleadings be amended after a final judgment has been rendered by the Supreme Court, and may a lower court entertain such amendments or further proceedings in an action thus finally decided?
RULING:
No. The Supreme Court ruled that after a final judgment has been rendered, the action is considered closed, and the time for amendment has passed. While Section 110 of the Code of Procedure in Civil Actions allows amendments “at any stage of the action,” this provision does not extend to allowing amendments after a final judgment has been entered and the case is closed.
The Court emphasized that allowing amendments after a final judgment would lead to indefinite litigation, preventing the final termination of a controversy. The Supreme Court in the original case could have reserved the right to amend the pleadings but did not, thereby rendering a final judgment.
Accordingly, the Supreme Court granted Juana Espiritu’s petition for writs of mandamus and prohibition. Judge Crossfield was ordered to issue an order of execution requiring Guash to return the personal property to Espiritu, and was prohibited from proceeding further under the amended complaint filed by Guash.