G.R. No. 148280 - Chong vs. Court of Appeals

Petitioner Loreta Agustin Chong, also known as Loreta Garcia Agustin, filed a complaint for annulment of contracts and recovery of possession against respondents spouses Pedro and Rosita de Guzman and Fortune Development Corporation.
Petitioner claimed to be the common-law wife of Augusto Chong.

On February 13, 1980, petitioner bought a parcel of land (subject lot) in San Dionisio, Rizal, from respondent corporation under Contract to Sell No. 195.
Petitioner executed a Special Power of Attorney (SPA) in favor of Augusto Chong, allowing him to sell or dispose of the subject lot and pay obligations.
Augusto, through the SPA, sold the subject lot to respondent spouses by a Transfer of Rights and Assumption of Obligation dated January 30, 1984, allegedly for P80,884.95, which petitioner claimed never received.
Petitioner denied selling a house on the subject lot to respondent spouses, claiming as forged the Deed of Sale dated February 24, 1987, because she was working abroad in Hong Kong at that time.
Petitioner also claimed ownership of a house in Manila that was rented by respondents without her consent.

Respondent spouses moved to dismiss the complaint for failure to state a cause of action; denied by the trial court.
Respondent spouses filed an Answer and later an Amended Answer with Counterclaim after being granted leave by the trial court upon oral motion.
Petitioner’s motion to strike out the Amended Answer for lack of prior written motion was denied by the trial court.
After trial on the merits, the trial court dismissed petitioner’s complaint and ordered her to pay moral damages (P50,000), attorney’s fees (P10,000), and costs.
The Court of Appeals affirmed the trial court’s decision.
Petitioner filed a petition for review before the Supreme Court.

Did the trial court err in admitting respondent spouses’ amended answer without a written motion for leave, violating Section 3, Rule 10 of the Rules of Court?
Was petitioner deprived of due process when respondent spouses allegedly failed to furnish copies of documents intended for trial, violating Section 6, Rule 18 of the Rules of Court?
Did the trial court err in upholding the validity and enforceability of the Transfer of Rights and Assumption of Obligation dated January 30, 1984?
Was the judgment based on the compromise agreement in Pasay City RTC Civil Case No. 1102-P void for lack of jurisdiction and unauthorized acts?
Are the Deed of Sale dated February 24, 1987, and ownership claims on the houses valid or forged?