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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