G.R. No. L-5952; March 26, 1953
OTILLA SOLDER DE OCAMPO, ET AL., petitioners, vs. ANATALIO C. MANALAC, ETC., ET AL., respondents.

FACTS

Petitioners Otilla Solder de Ocampo, et al., were plaintiffs in Civil Case No. 43 of the Court of First Instance of Sorsogon against respondent Saturnino Benito. The trial court rendered a decision declaring Benito rightfully entitled to ownership of one-half of the disputed parcel, ordering partition, and sentencing the plaintiffs to deliver possession of that half to Benito until partition. It also ordered the plaintiffs to pay Benito P1,500 yearly. On appeal, the Court of Appeals reversed the portion of the judgment condemning petitioners to pay the P1,500 yearly damages, affirming the judgment in all other respects. The Court of Appeals held the award unjustified as such damages were not claimed in Benito’s pleadings, and admitting evidence on it deprived petitioners of their day in court. After this decision became final and the records were returned to the trial court, respondent Benito filed a motion for admission of a supplemental answer praying that petitioners be ordered to pay the same sum of P1,500 yearly from 1945—the same relief eliminated by the final decision of the Court of Appeals. Over petitioners’ objection, the respondent judge admitted the supplemental answer, gave petitioners time to plead, and set the case for hearing. Petitioners’ motion for reconsideration was denied, prompting this petition for certiorari.

ISSUE

Whether the respondent judge acted with grave abuse of discretion in admitting the supplemental answer after the Court of Appeals’ decision had become final, which sought to recover the same damages (P1,500 yearly) that were expressly disallowed and eliminated by the final judgment.

RULING

Yes. The Supreme Court set aside the orders of the respondent judge admitting the supplemental answer. The Court held that amendments or supplemental pleadings are not admissible “after the rendition of a final judgment.” While amendments may be permitted even after a final decision in certain exceptional circumstances (e.g., to cure a defect of party plaintiffs without prejudice), such is not the case here. The supplemental answer sought to alter a final judgment on a substantial matter—specifically, to recover damages already finally disallowed by the Court of Appeals. The Court rejected the argument that the action, being one for partition, had no final judgment until the portions were adjudicated, noting that Rule 71, Section 8 (on recovery of shares of rents and profits) contemplates a case where a proper claim has been timely pleaded, not where a decision has become final expressly eliminating such an award. The Court emphasized that Benito was aware of his claim for damages, as evidenced by his prior attempt to present evidence on it during trial, and could have timely pleaded it. Allowing the supplemental answer would violate the principle of finality of judgments.