G.R. No. 250542 - Heirs of Pio Tejada and Soledad Tejada, represented by Pio Domingo Tejada vs. Garry B. Hay, in substitution of Myrna L. Hay

The dispute involves a complaint for quieting of title filed by Myrna L. Hay against the heirs of Pio Tejada and Soledad Tejada, represented by Pio Domingo Tejada.
Myrna alleged that the disputed land was originally sold by petitioners’ father, Pio Tejada, to Haru Gen Beach Resort and Hotel Corporation on November 12, 1988, and that she later acquired the property when Haru Gen sold it to her on March 5, 1992.
Additionally, Myrna presented another deed dated May 28, 1997 purporting that Pio Tejada himself sold the same property to her.

Petitioners filed an Answer dated August 26, 2016, contesting Myrna’s claims by arguing that the deeds purporting to convey title were falsified, noting that their father’s signature was forged on one of the deeds.
The case was initially set for pre-trial on September 28, 2016 but, due to its multiple postponements, the pre-trial conference eventually took place on June 28, 2017.

With the case progressing and after the conclusion of preliminary matters, the RTC issued a Pre-Trial Order on June 28, 2017 scheduling the trial to begin on October 25, 2017.
Instead of proceeding to trial, the RTC later referred the case to mediation on July 19, 2018 via an Order dated June 27, 2018.
On July 6, 2018, petitioners filed a Motion for Leave to File an Amended Answer with Counterclaim.

The amended pleading aimed to clarify which allegations in the complaint were admitted or denied.
It also asserted compulsory counterclaims alleging the nullification of the alleged falsified deeds, the declaration of petitioners’ ownership over the property, and the grant of damages and attorney’s fees.

The amendment was necessary to hasten the determination of the merits based on the actual facts.
It had been filed before the trial even though the case had entered mediation, and thus should be permitted given the general policy favoring amendments.

In response, the RTC denied the Motion for Leave on August 17, 2018, holding that the case had already undergone preliminary and pre-trial conferences.

Petitioners’ counsels were further ordered to show cause for their erroneous assertion that the case had not yet entered the preliminary stage.

A subsequent Motion for Reconsideration filed on this issue was also denied on December 3, 2018.

Petitioners elevated the issue through a Petition for Certiorari before the Court of Appeals, arguing that:

Amendments are favored at any stage of proceedings if not intended to delay the case.
The motion for leave was timely since it was filed before trial and during mediation.
The amendment would clarify critical defenses and counterclaims needed for a complete resolution of the controversy.

Meanwhile, respondent Garry B. Hay (in substitution for Myrna L. Hay) argued that the Amended Answer, written in a more scholarly manner, merely repeated arguments in the original Answer and would lead to further delay.

The RTC denied petitioners’ Motion for Leave to File the Amended Answer based on its determination that the case had fully proceeded through the preliminary and pre-trial stages.
The Court of Appeals subsequently affirmed the RTC’s orders in its Decision dated August 7, 2019 and Resolution dated November 20, 2019, dismissing the petition for certiorari raised by the petitioners.

Whether the trial court abused its discretion in denying the petitioners’ Motion for Leave to File an Amended Answer with Counterclaim.
Whether the filing of the amendment after the case had undergone preliminary and pre-trial conferences should be considered dilatory or merely a timely effort to clarify and complete the pleadings.
Whether the general judicial policy favoring liberal amendment to pleadings applies even when a case is already in mediation or past the pre-trial phase.
Whether the substance of the Amended Answer, which reiterates the defense that the deeds are falsified while also adding more precise admissions, is necessary for the just and expeditious resolution of the merits.