Simon vs. Commission on Human Rights G.R. No. 100150 [January 5, 1994]

 CONSTITUTIONAL LAW

Simon vs. Commission on Human Rights

G.R. No. 100150 [January 5, 1994]

 EN BANC, VITUG, J.

 

Powers of Commission on Human Rights (CHR) to investigate civil and political rights violation of citizen; 

The Commission on Human Rights (CHR) is limited to investigating violations of civil and political rights, as defined by the Constitution. Economic rights and privileges, such as the right to engage in business, do not fall under the CHR’s jurisdiction unless they are directly linked to civil or political rights violations. Furthermore, the CHR’s contempt powers are confined to enforcing compliance with its investigative mandates and cannot be used to enforce orders in matters outside its constitutional authority.

 

In July 1990, the Quezon City government issued a demolition notice to vendors occupying stalls and shanties along North EDSA. The notice, signed by petitioner Carlos Quimpo, instructed the private respondents—members of the North EDSA Vendors Association—to vacate the premises within three days to make way for the development of a “People’s Park.” The respondents sought assistance from the Commission on Human Rights (CHR), filing a complaint to stop the demolition. 

The CHR issued several orders to halt the demolition and provide financial assistance to the affected vendors. It also cited the petitioners for contempt when the demolition proceeded despite its directives. The petitioners challenged the CHR’s jurisdiction, arguing that the issues raised did not fall under human rights violations involving civil or political rights as envisioned by the Constitution. They claimed that the respondents’ rights to engage in business were merely privileges, not enforceable human rights.

 

Whether or not the CHR have jurisdiction to investigate the demolition of vendors’ stalls and shanties as a human rights violation involving civil and political rights. 

NO. The Supreme Court ruled that the CHR’s jurisdiction is confined to investigating violations of civil and political rights and that it exceeded its authority in this case. The Court invalidated the CHR’s orders to stop the demolition and its imposition of contempt penalties. 

The Court explained that civil rights pertain to an individual’s entitlements as a citizen, such as property rights, equal protection under the law, and contractual freedom. Political rights relate to participation in governmental functions, such as suffrage and holding public office. Human rights violations, as contemplated by the Constitution, are those involving severe breaches of civil and political rights, such as torture, enforced disappearances, or political detention. 

The Court found that the demolition of stalls and shanties, planned for the construction of a public park, did not constitute a human rights violation involving civil or political rights. The claimed “right to engage in business” was a mere privilege and not among the inalienable rights protected under the CHR’s jurisdiction. 

On the CHR’s power to cite for contempt, the Court held that this authority is limited to enforcing its operational guidelines and rules of procedure necessary to carry out its investigative function. The CHR’s contempt powers do not extend to enforcing resolutions on matters beyond its jurisdiction, such as halting a demolition based on alleged economic rights violations.

 

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Philippine Blooming Mills vs. Philippine Blooming Mills G.R. No. L-31195 [June 5, 1973]

 CONSTITUTIONAL LAW

Philippine Blooming Mills vs. Philippine Blooming Mills

G.R. No. L-31195 [June 5, 1973]

EN BANC, MAKASIAR, J.

 

Bill of Rights; Freedom to Associate

Government agencies are strictly limited to the powers expressly conferred upon them by their enabling statutes. Any act or contract entered into beyond the scope of such powers is ultra vires and void.

 

The petitioner Philippine Blooming Mills Employees Organization (hereinafter referred to as PBMEO) is a legitimate labor union composed of the employees of the respondent Philippine Blooming Mills Co., Inc., and petitioners Nicanor Tolentino, Florencio Padrigano, Rufino Roxas, Mariano de Leon, Asencion Paciente, Bonifacio Vacuna, Benjamin Pagcu and Rodulfo Munsod are officers and members of the petitioner Union. PBMEO decided to stage a mass demonstration in front of Malacañang to express their grievances against the alleged abuses of the Pasig Police. 

Petitioners claim that on March 1, 1969, they decided to stage a mass demonstration at Malacañang on March 4, 1969, in protest against alleged abuses of the Pasig police, to be participated in by the workers in the first shift (from 6 A.M. to 2 P.M.) as well as those in the regular second and third shifts (from 7 A.M. to 4 P.M. and from 8 A.M. to 5 P.M., respectively); and that they informed the respondent Company of their proposed demonstration. The Philippine Blooming Mills Inc., called for a meeting with the leaders of the PBMEO after learning about the planned mass demonstration. During the meeting, the planned demonstration was confirmed by the union. But it was stressed out by the union that the demonstration was not a strike against the company but was in factual exercise of the laborers inalienable constitutional right to freedom of expression, freedom of speech and freedom for petition for redress of grievances. 

The company asked them to cancel the demonstration for it would interrupt the normal course of their business which may result in the loss of revenue. This was backed up with the threat of the possibility that the workers would lose their jobs if they pushed through with the rally. A second meeting took place where the company reiterated their appeal that while the workers may be allowed to participate, those from the 1st and regular shifts should not absent themselves to participate, otherwise, they would be dismissed. Since it was too late to cancel the plan, the rally took place and the officers of the PBMEO were eventually dismissed for a violation of the ‘No Strike and No Lockout’ clause of their Collective Bargaining Agreement. The lower court decided in favour of Philippine Blooming Mills Co., Inc., and the officers of the PBMEO were found guilty of bargaining in bad faith. The PBMEO’s motion for reconsideration was subsequently denied by the Court of Industrial Relations for being filed two days late.

 

Whether or not the workers who joined the strike violated the Collective Bargaining Agreement?

NO. While the Bill of Rights also protects property rights, the primacy of human rights over property rights is recognized. Because these freedoms are "delicate and vulnerable, as well as supremely precious in our society" and the "threat of sanctions may deter their exercise almost as potently as the actual application of sanctions," they "need breathing space to survive," permitting government regulation only "with narrow specificity." Property and property rights can be lost thru prescription; but human rights are imprescriptible. In the hierarchy of civil liberties, the rights of free expression, free assembly and petition, are not only civil rights but also political rights essential to man's enjoyment of his life, to his happiness and to his full and complete fulfillment. Thru these freedoms the citizens can participate not merely in the periodic establishment of the government through their suffrage but also in the administration of public affairs as well as in the discipline of abusive public officers. The citizen is accorded these rights so that he can appeal to the appropriate governmental officers or agencies for redress and protection as well as for the imposition of the lawful sanctions on erring public officers and employees.      

 

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Iron and Steel Authority (ISA) v. Court of Appeals G.R. No. 102976 [October 25, 1995]

 CONSTITUTIONAL LAW

Iron and Steel Authority (ISA) v. Court of Appeals

G.R. No. 102976 [October 25, 1995]

THIRD DIVISION, FELICIANO, J.

 

Ultra Vires Powers

 

Government agencies are strictly limited to the powers expressly conferred upon them by their enabling statutes. Any act or contract entered into beyond the scope of such powers is ultra vires and void.

 

The Iron and Steel Authority (ISA) entered into a loan agreement with Maria Cristina Fertilizer Corporation (MCFC), a private entity engaged in fertilizer production. Under the agreement, ISA provided a loan to MCFC to finance the purchase of equipment and other operational needs. MCFC failed to repay the loan upon maturity, prompting ISA to file a collection case against MCFC. 

MCFC, in its defense, argued that the loan agreement was void for being ultra vires, claiming that ISA, as a government agency, lacked the authority to grant loans. The trial court ruled in favor of MCFC, declaring the loan agreement void. ISA appealed to the Court of Appeals, which upheld the trial court’s decision. ISA then elevated the case to the Supreme Court.

 

Whether the loan agreement entered into by the Iron and Steel Authority with Maria Cristina Fertilizer Corporation is valid and binding. 

NO. The Supreme Court ruled in favor of the Court of Appeals and Maria Cristina Fertilizer Corporation, affirming the nullity of the loan agreement. The Court emphasized that government agencies like the Iron and Steel Authority must strictly adhere to their statutory mandates. ISA’s enabling law did not grant it the authority to engage in lending activities or act as a financial intermediary. Thus, the loan agreement was ultra vires and void. 

The Court noted that while ISA had the mandate to develop the iron and steel industry, lending money to private entities was not within the scope of its legal powers. Any act performed beyond the authority granted by law is considered ultra vires and has no legal effect. 

Furthermore, the Court stressed that contracts entered into by government agencies must conform to their statutory powers to avoid overreach and ensure accountability. In this case, the absence of explicit authority for ISA to grant loans rendered the agreement unenforceable.

 

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Didipio Earth Savers Multipurpose Association vs Gozun G.R. No. 157882 [March 30, 2006]

 CONSTITUTIONAL LAW

Didipio Earth Savers Multipurpose Association vs Gozun

G.R. No. 157882 [March 30, 2006]

FIRST DIVISION, CHICO-NAZARIO, J.

 

Police Power; Eminent Domain; Delegation of Legilative Power to Administrative Agencies

 

Republic Act No. 7942 (Philippine Mining Act of 1995) and the DENR’s implementing rules and regulations are valid and constitutional. Delegation of legislative authority to administrative agencies is permissible when it provides specificity and ensures effective implementation of the law.

 

In 1987, Cory rolled out EO 279 w/c empowered DENR to stipulate with foreign companies when it comes to either technical or financial large scale exploration or mining. In 1995, Ramos signed into law RA 7942 or the Philippine Mining Act. In 1994, Ramos already signed an FTAA with Arimco Mining Co, an Australian company. The FTAA authorized AMC (later CAMC) to explore 37,000 ha of land in Quirino and N. Vizcaya including Brgy Didipio.After the passage of the law, DENR rolled out its implementing RRs. Didipio petitioned to have the law and the RR to be annulled as it is unconstitutional and it constitutes unlawful taking of property. 

The Didipio Earth-Savers’ Multi-Purpose Association, Inc. (DESAMA) and several individuals petitioned to nullify a Financial or Technical Assistance Agreement (FTAA) granted by the Department of Environment and Natural Resources (DENR) to Climax-Arimco Mining Corporation (CAMC). They argued that Republic Act No. 7942, the Philippine Mining Act of 1995, and its implementing rules and regulations (IRRs) were unconstitutional. Specifically, they claimed the law violated the constitutional mandate to protect natural resources, failed to safeguard the rights of indigenous peoples, and infringed on the constitutional right to a balanced and healthful ecology. Additionally, the petitioners contended that RA 7942 improperly delegated legislative powers to the DENR by authorizing it to issue detailed regulations. 

The DENR and CAMC argued that the Mining Act and its IRRs were constitutional and consistent with the constitutional framework for the responsible utilization of natural resources. They emphasized that the law provided safeguards for environmental protection and indigenous peoples' rights and was designed to support national development.

 

Whether RA 7942 (Philippine Mining Act of 1995) and the DENR’s implementing rules and regulations (IRRs) are unconstitutional. 

NO. The Supreme Court ruled in favor of the DENR and CAMC, upholding the validity and constitutionality of RA 7942 and its implementing rules and regulations. The Court ruled that the Mining Act of 1995 was enacted to operationalize the constitutional mandate allowing the state to utilize natural resources for economic development. The law is consistent with Article XII of the 1987 Constitution, which recognizes both the state’s authority to manage natural resources and the need to protect the environment. 

The Court held that RA 7942 provided the necessary safeguards to ensure the responsible utilization of natural resources. It required environmental impact assessments, consultations with affected communities, and adherence to strict environmental standards. Furthermore, the law protected the rights of indigenous peoples through mechanisms such as free, prior, and informed consent (FPIC) for mining activities within ancestral domains, as mandated by the Indigenous Peoples’ Rights Act (IPRA). 

On the issue of delegation of legislative power, the Court ruled that the delegation of authority to the DENR to craft implementing regulations was valid. The delegation was specific and necessary to enable the DENR, as the agency with technical expertise, to execute the law effectively. The regulations issued by the DENR were deemed consistent with the policy objectives of RA 7942. 

The Court also emphasized the need to balance the constitutional right to a balanced and healthful ecology with the state's duty to promote economic development. RA 7942 and its IRRs embody this balance by allowing mining operations under strict environmental controls and community protections. Petitioners failed to show any concrete violations of constitutional or statutory rights.

 

 

 

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City Government of Quezon vs. Judge Ericta GR No. L-34915 [June 24, 1983]

 CONSTITUTIONAL LAW

City Government of Quezon vs. Judge Ericta

GR No. L-34915 [June 24, 1983]

FIRST DIVISION, GUTIERREZ, JR., J

 

Misuse of Police Power; Lawful Means; Unconstitutional Taking of Property

 

The exercise of police power cannot be used as a substitute for eminent domain when the state or local government seeks to take private property for public use. Such an act requires the payment of just compensation and adherence to due process. Ordinances that compel private property owners to donate land for public purposes, without compensation, constitute an unconstitutional taking of property.

 

An ordinance was promulgated in Quezon city which approved the the regulation of establishment of private cemeteries in the said city. According to the ordinance, 6% of the total area of the private memorial park shall be set aside for charity burial of deceased persons who are paupers and have been residents of QC. Himlayang Pilipino, a private memorial park, contends that the taking or confiscation of property restricts the use of property such that it cannot be used for any reasonable purpose and deprives the owner of all beneficial use of his property. It also contends that the taking is not a valid exercise of police power, since the properties taken in the exercise of police power are destroyed and not for the benefit of the public.

 

Whether or not the ordinance requiring private cemeteries to allocate 6% of their area for pauper burials constitute a valid exercise of police power.

 

NO. The ordinance made by Quezon City is not a valid way of taking private property. The ordinance amounted to a confiscation of private property without just compensation, violating the constitutional guarantee against deprivation of property without due process. Police power is intended to regulate the use or enjoyment of property for the public good, not to outright take or confiscate private property for public use. The ordinance crossed this boundary by compelling private cemeteries to donate land without compensation. 

The ordinance is actually a taking without compensation of a certain area from a private cemetery to benefit paupers who are charges of the municipal corporation; instead of building or maintaining public cemeteries. If the city wished to use private property for public purposes, such as paupers' burials, it should have exercised its power of eminent domain, which requires payment of just compensation, rather than relying on the general welfare clause. State's exercise of the power of expropriation requires payment of just compensation. The ordinance could not be justified under the general welfare clause, as there was no reasonable connection between the requirement to set aside private land and the promotion of public health, safety, or welfare. The provision merely shifted the city’s responsibility to provide public cemeteries onto private operators. Passing the ordinance without benefiting the owner of the property with just compensation or due process, would amount to unjust taking of a real property.

 

 

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BAUTISTA VS. JUNIO G.R. No L-50908 [January 31, 1984]

 CONSTITUTIONAL LAW

BAUTISTA VS. JUNIO

G.R. No L-50908 [January 31, 1984]

EN BANC, FERNANDO C.J

 

Lawful Subject; Police Power; LOI; No Violation of Equal Protection Clause

 

Police power refers to the capacity of the states to regulate behavior and enforce order within their territory to promote the health, safety, morals, and general welfare of their inhabitants.

 

The constitutionality of Letter of Instruction (LOI) No. 869, a response to protracted oil crisis, banning the use of private motor vehicles with H (heavy) and EH (extra heavy) plates on week-ends and holidays, was assailed for being allegedly violative of the due process and equal protection guarantees of the Constitution.

 

Petitioners also contends that Memorandum Circular No. 39 issued by herein respondents imposing penalties of fine, confiscation of the vehicle and cancellation of license of owners of the above specified vehicles found violating such LOI, is likewise unconstitutional, for being violative of the doctrine of “undue delegation of legislative power.”

 

Respondents denied the above allegations.

 

Whether or not Letter of Instruction 869 as implemented by Memorandum Circular No. 39 is violative of certain constitutional rights.

 

NO. The disputed regulatory measure is an appropriate response to a problem that presses urgently for solution, wherein its reasonableness is immediately apparent. Thus, due process is not ignored, much less infringed. The exercise of police power may cut into the rights to liberty and property for the promotion of the general welfare. Those adversely affected may invoke the equal protection clause only if they can show a factual foundation for its invalidity.

 

Moreover, since LOI No. 869 and MC No. 39 were adopted pursuant to the Land Transportation and Traffic Code which contains a specific provision as to penalties, the imposition of a fine or the suspension of registration under the conditions therein set forth is valid with the exception of the impounding of a vehicle.

 

 

Important Legal Principles

1. Police Power:
• The case emphasizes the extent of police power, which is the inherent authority of the state to enact laws and regulations to promote public welfare, safety, and morals. The decision recognized that local governments possess police power to regulate land use and zoning.
2. Due Process:
• The ruling also highlighted the importance of due process in the exercise of police power. Even though the government has broad authority, it must not infringe upon individual rights without following appropriate legal procedures. The principles of fairness and justice in regulatory actions were upheld.
3. Lawful Subject:
• The Court discussed the necessity for regulations enacted under police power to pertain to lawful subjects. The regulations must be justified on legitimate grounds pertinent to public health, safety, or morals and must also align with constitutional safeguards.

 
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Ortiz v. Forever Richsons Trading Corp., G.R. No. 238289, [January 20, 2021]

 CASE DIGEST 

Ortiz v. Forever Richsons Trading Corp.

 G.R. No. 238289, [January 20, 2021]

EN BANC, LOPEZ, M.V

 

Legitimate Job Contracting

 

While the existence of registration in favor of a contractor is a strong badge of legitimacy, the elements of substantial capital, or investment and control over the workers may be examined to rebut the presumption of regularity to prove that a contractor is a labor-only contractor. 

 

Oscar S. Ortiz filed a complaint against Forever Richsons Trading Corporation, now Charverson Wood Industry Corporation, alleging illegal dismissal and monetary claims. He claimed to be a regular employee, having served them for two years after the expiration of his initial 5-month contract, and performed tasks essential to the company's plywood manufacturing and marketing. He was allegedly terminated for refusing to sign a new contract and blank papers. The respondents argued that they contracted Workpool Manpower, a registered independent job contractor, for supplying workers, and Oscar signed a contract with them. Workpool Manpower confirmed Oscar's employment with them, terminated upon contract expiration. The Labor Arbiter (LA) dismissed Oscar's complaint for not including Workpool Manpower as a necessary party, deeming him their regular employee. The NLRC and the CA affirmed this decision, recognizing Workpool Manpower as Oscar's employer.

 

Whether or not Workpool Manpower is a legitimate labor contractor. 

NO. Workpool Manpower is a labor-only contractor. Article 106 of the Labor Code defines labor-only contracting as an arrangement where a person supplies workers to an employer to perform activities directly related to the employer's principal business without substantial capital or investment. Legitimate contracting requires the contractor to have registration, carry out work independently, have substantial capital, and ensure compliance with labor laws. Despite Workpool Manpower's registration, it lacked substantial capital and control over workers. Oscar's employment directly with the respondents, performing tasks integral to their plywood manufacturing, indicated labor-only contracting. The agreement between respondents and Workpool Manpower showed the latter's sole obligation was to provide workers. Additionally, Oscar's use of respondents' machinery and receipt of wages from them indicated his direct employment with them. Therefore, Workpool Manpower was deemed a mere labor supplier.

 

Whether or not Oscar is an employee of and was illegally dismissed.

YES. Forever Richsons Trading Corporation, are the employers of Oscar who they illegally dismissed. Due to the prohibited form of contracting between Workpool Manpower and the respondents, it is unnecessary to include Workpool Manpower as a party to the case. In labor-only contracting, the principal and contractor's personalities merge, making Workpool Manpower a mere representative of the respondents. Despite the respondents claiming Oscar's termination was due to the expiration of his contract, Oscar had worked for them for over a year, performing tasks integral to their plywood manufacturing business. Therefore, Oscar is considered a regular employee, and his dismissal must be for a valid cause, not merely because of the contract's end. Consequently, the petition is granted, and Oscar S. Ortiz is declared illegally dismissed. The respondents are ordered to reinstate Oscar to his former position without loss of seniority rights and privileges and to provide backwages and other benefits from the time of his dismissal to the time of actual reinstatement.

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Metropolitan Bank and Trust Co. v. Radio Philippines Network, Inc., G.R. No. 190517, [July 27, 2022]

 CASE DIGEST

Metropolitan Bank and Trust Co. v. Radio Philippines Network, Inc.

 G.R. No. 190517, [July 27, 2022]

SECOND, LOPEZ, M.V 

Execution of Judgments; Satisfaction by levy; Escrow Funds; Garnishment

 

It is through the service of the writ of garnishment that the trial court acquires jurisdiction to bind the third person or garnishee to compliance with all its orders and processes. Courts cannot require third parties to comply with all its orders and processes absent the service of a writ of garnishment. 

 

The RTC initially rendered a judgment against Traders Royal Bank and Security Bank, ordering them to pay damages and attorney's fees to Radio Philippines Network (RPN), Intercontinental Broadcasting Corporation (IBC), and Banahaw Broadcasting Corporation (BBC). The CA, however, absolved Security Bank from liability and held Traders Royal solely responsible for the damages. Traders Royal appealed to the SC (G.R. No. 138510). 

Subsequently, the broadcasters sought a writ of execution from the RTC, targeting Traders Royal's assets and an escrow fund in Metrobank was established as part of a Purchase and Sale Agreement (PSA) with Bank of Commerce, approved by the Bangko Sentral ng Pilipinas (BSP). The RTC granted the writ, including the escrow fund. Metrobank, where the escrow fund was deposited, objected, arguing it was not a party to the case and questioned the RTC's jurisdiction over it.

 

Whether or not it was proper for the RTC to issue the writ of execution against the escrow fund. 

NO. The RTC cannot require Metrobank to comply with all its orders and processes absent the service of a writ of garnishment. The execution process for a money judgment entails the executing officer first demanding immediate payment from the judgment debtors in cash, certified bank check, or acceptable mode of payment. If payment cannot be made using these methods, judgment debtors can select which personal properties to levy upon. If they fail to exercise this right or cannot be located, they waive it, allowing the executing officer to levy personal properties, then real properties if necessary.

Garnishment is another method, allowing the seizing of credits owed to the judgment debtors by a third party. In this case, the RTC deviated from the prescribed process by directing enforcement against all assets of Traders Royal Bank (TRB) and the escrow fund, without first demanding payment. The proper procedure involves demanding payment from TRB first, then levying properties if payment cannot be made, followed by service of a writ of garnishment to bind third parties. Service of a writ of garnishment is necessary for the court to bind third parties like Metrobank. Therefore, the RTC should deny the request for subpoena and follow the correct execution procedure to ascertain the status of the escrow account.

 

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Heirs of Tejada v. Hay, G.R. No. 250542, [October 10, 2022]

 CASE DIGEST

Heirs of Tejada v. Hay

 G.R. No. 250542, [October 10, 2022]

SECOND, LOPEZ, M.V 

Amendment to Pleadings; Motion to Admit Amended Answer;

 

Bona fide amendments to pleadings are allowed at any stage of the proceedings. Thus, as a matter of judicial policy, courts are impelled to treat motions for leave to file amended pleadings with liberality, the paramount consideration being that it does not appear that the motion for leave was with intent to delay the proceedings. 

 

Myrna L. Hay filed a Complaint for Quieting of Title against petitioners, alleging that their father, Pio, sold the disputed parcel of land to her in 1997, supported by a Deed of Absolute Sale (DoAS). Petitioners countered, claiming that the deeds of sale were falsified as their father's signature was forged. They sought dismissal of Myrna's Complaint. Later, petitioners filed a Motion for Leave for an Amended Answer, clarifying their position and asserting compulsory counterclaims, including nullification of the deeds of sale and declaration of their ownership over the property. The RTC denied the motion, citing the case's progression through preliminary and pre-trial conference. Petitioners appealed to the CA via a Petition for Certiorari, contesting the denial, which the CA dismissed.

 

Whether or not the denial of the Motion for Leave to File Amended Answer was proper. 

NO. The RTC gravely abused its discretion in denying the Motion for Leave on the ground that the case had already gone through preliminary/pre-trial conference. Sections 1 and 3, Rule 10 of the Rules of Court permit amendments to pleadings to ensure the speedy determination of the actual merits of a controversy, without regard to technicalities. The only limitation is if the court finds that the motion to amend was made with intent to delay. In this case, the RTC and CA denied the Motion for Leave mainly because the case had progressed through preliminary and pretrial conferences. However, there was no indication that the motion was filed with intent to delay. Amendments to pleadings are generally favored to aid in deciding cases on their merits and avoiding multiple lawsuits. The admission of the Amended Answer was warranted as it contained crucial allegations necessary for the proper resolution of the case. Therefore, the RTC had no valid reason to deny the motion for leave

 

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