G.R. No. 157107 - Alpine Lending Investors vs. Corpuz

In Civil Case No. C-20124, Estrella Corpuz, the respondent, filed a complaint for replevin against Alpine Lending Investors (one of the petitioners) and Zenaida Lipata.
Estrella Corpuz alleged that Zenaida Lipata, her former neighbor, misappropriated her vehicle through deceit.
The incident began when Zenaida purportedly offered assistance in securing a Garage Franchise from the Land Transportation Office (LTO) for the respondent.
Zenaida took the original registration papers of the respondent’s vehicle—a Toyota Tamaraw FX with Plate No. UMR 660—and later used them to claim the vehicle from a repair shop (Richmond Auto Center).
After retrieving the vehicle, Zenaida disappeared with it, prompting the respondent to report the incident to the LTO Muntinlupa City Branch.

The LTO informed the respondent that the vehicle had been mortgaged with Alpine Lending Investors.
The respondent was shown a Chattel Mortgage Contract that bore her forged signature, linking the fraudulent mortgage to Alpine.
Upon being notified of the mortgage, Alpine promised to return the vehicle on the condition that Zenaida be criminally charged.

The respondent filed complaints for falsification of private document and estafa against Zenaida with the Metropolitan Trial Court of Caloocan City, resulting in the issuance of a warrant of arrest.
Instead of filing an answer to the replevin complaint, Alpine submitted a motion to dismiss on the grounds that it was not a juridical person and thus not a proper party in the case.
In an Order dated September 2, 2002, the RTC denied Alpine’s motion to dismiss.
Alpine filed a motion for reconsideration, which was similarly denied by the RTC.

The RTC directed the respondent to file an amended complaint within ten (10) days, which was filed with a Motion to Admit Amended Complaint two (2) days late.
The RTC, in an Order dated December 13, 2002, admitted the amended complaint despite the slight delay.
On January 3, 2003, Alpine filed a Motion to Expunge the respondent’s motion to admit the amended complaint, arguing the absence of a notice of hearing.
The respondent countered by stating that a notice of hearing was not necessary because her motion was “non-litigated.”
The RTC denied Alpine’s motion to expunge on January 24, 2003, and a subsequent motion for reconsideration was also denied on January 28, 2003.

The petition arose from the issue of whether the trial court erred in admitting the respondent’s amended complaint.
The legal question centered on the interpretation of Sections 1 and 2, Rule 10 of the 1997 Rules of Civil Procedure regarding amendments of pleadings, specifically:

That amendments may be made as a matter of right when no responsive pleading has been filed.
The classification of a motion to dismiss (filed by Alpine) as non-responsive, thereby allowing the respondent to amend her complaint.

The Supreme Court, referencing its prior ruling in Breslin v. Luzon Stevedoring Co., held that the duty of the trial court to admit the amended complaint is ministerial.

Whether the trial court erred in admitting the respondent’s amended complaint despite it being filed two days beyond the prescribed period.
Whether the respondent was entitled to amend her complaint as a matter of right under Sections 1 and 2, Rule 10 of the 1997 Rules of Civil Procedure, given that Alpine’s motion to dismiss was not considered a responsive pleading.
Whether the trial court’s duty to admit the amended complaint was purely ministerial, thereby mandating its acceptance without substantive review.