G.R. No. 107824 - Superclean Services Corp. vs. Court of Appeals

Petitioner, Superclean Services Corporation, filed a complaint on November 8, 1989, before the Regional Trial Court of Manila for Mandamus/Certiorari With Preliminary Injunction And/Or Restraining Order.
The original complaint alleged that petitioner was the "lowest or best bidder" in the public bidding for janitorial services for the year 1990, but respondent Home Development Mutual Fund unjustifiably refused to award the contract.

In its answer, respondent contended that no bid submitted met the terms and conditions agreed upon during the pre-bidding conference held on September 6, 1989.
The trial court granted petitioner’s application for a preliminary injunction, ordering respondent to desist from conducting a rebidding, while also allowing respondent to engage janitorial services on a temporary, month-to-month basis to ensure office maintenance.

On July 24, 1991, petitioner filed a "Supplemental Complaint" alleging that due to the delay in the resolution of the case, the contract for janitorial services—pertaining to the year 1990—had become moot and academic.
Petitioner claimed that the passage of the contract year resulted in undue damage, specifically:

Instead of continuing to pursue the prayer for a writ of mandamus to compel the award of the contract, petitioner sought recovery of damages as an alternative remedy.

The trial court on August 23, 1991, denied the motion for the admission of the Supplemental Complaint, stating it would substantially change the issues and prejudice respondent’s rights.
Petitioner’s subsequent motion for reconsideration was also denied.
The Court of Appeals, in its decision on August 5, 1992, upheld the trial court’s denial, holding that:

The relief sought in the Supplemental Complaint differed materially from the original complaint’s prayer;
A supplemental pleading should aid the original pleading rather than substitute it entirely;
The change in relief introduced new issues and potential prejudice to the respondent.

Petitioner’s motion for reconsideration at the appellate level was denied on October 30, 1992, prompting the petition for certiorari before the Supreme Court.

The petition relies on Rule 10 of the Rules of Court regarding supplemental pleadings, which allows a party to serve additional facts or events that occurred after the original pleading.
In the present case, the supervening event (the lapse of the contract year) was cited as justification for seeking damages rather than the originally prayed-for contract award.
Despite this, the Supreme Court viewed the Supplemental Complaint as effectively an amendment to the original complaint, not as a change in the fundamental cause of action.

Whether the filing of the Supplemental Complaint, which sought a different relief (damages in lieu of the contract award), was proper under the Rules of Court.
Whether the trial court committed grave abuse of discretion by refusing to admit the Supplemental Complaint on the grounds that it would change the issues and prejudice the respondent’s rights.
Whether such amendments or supplemental pleadings, which alter the remedy but not the foundational cause of action, are consistent with the principle of liberal amendment in aid of justice.
Whether the supervening event (expiration of the contract period) justified the change in remedy without altering the essential allegation of respondent’s unjustified refusal to award the contract.