Case Summary (G.R. No. 250542)
Background of the Dispute
The case stems from a Complaint for Quieting of Title filed by Myrna L. Hay against the petitioners. Myrna claims that the petitioners' father, Pio, conveyed the disputed property to Haru Gen Beach Resort and Hotel Corporation on November 12, 1988, as evidenced by a Deed of Absolute Sale. Myrna later acquired the property when Haru Gen sold it to her on March 5, 1992. Additionally, she produced a second Deed of Absolute Sale, allegedly showing that Pio sold the same property to her on May 28, 1997.
Initial Pleadings and Procedural History
In response, the petitioners submitted an Answer on August 26, 2016, seeking the dismissal of Myrna's Complaint, contending that the deeds allegedly supporting her claims were falsified and signed with a forged signature. The pre-trial was initially set for September 28, 2016, but was postponed multiple times, with the actual pre-trial occurring on June 28, 2017, followed by a Pre-Trial Order issued by the Regional Trial Court (RTC) scheduling the trial to begin on October 25, 2017.
Motion for Leave to Amend Answer
On July 6, 2018, the petitioners filed a Motion for Leave to Admit an Amended Answer, which aimed to clarify matters and expedite the court's determination of the actual merits of the case. This Amended Answer specified which allegations in the Complaint were admitted or denied and included counterclaims for nullification of the deeds presented by Myrna, a declaration of ownership by the petitioners, and a demand for damages.
RTC's Denial of Motion for Leave
The RTC denied the Motion for Leave on August 17, 2018, asserting that the case had already undergone preliminary and pre-trial conferences, which the petitioners contested as having been misinterpreted due to mediation proceedings. The petitioners filed an Explanation to clarify their understanding of the proceedings, subsequently submitting a Motion for Reconsideration, which was also denied on December 3, 2018.
Appeal to the Court of Appeals
Challenging the RTC's rulings, the petitioners filed a Petition for Certiorari with the Court of Appeals (CA), asserting grave abuse of discretion in denying their Motion for Leave. However, the CA upheld the RTC's decision in its August 7, 2019 ruling, finding no grave abuse of discretion and concluding that the Amended Answer was unnecessary as the original Answer already contained the material defenses.
Supreme Court's Ruling
Upon review, the Supreme Court found merit in the petitioners' claims. It emphasized that amendments to pleadings are favored at any stage, particularly before trial, emphasizing that the determination of whether to grant a Motion for Leave
...continue readingCase Syllabus (G.R. No. 250542)
Case Background
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by the petitioners against the Decision dated August 7, 2019, and the Resolution dated November 20, 2019, of the Court of Appeals (CA).
- The petitioners, Heirs of Pio and Soledad Tejada, questioned the CA's dismissal of their Petition for Certiorari concerning the Orders of the Regional Trial Court (RTC) in Civil Case No. 2471, which denied their Motion for Leave to file an Amended Answer with Counterclaim.
- The origins of the controversy stem from a Complaint for Quieting of Title initiated by Myrna L. Hay against the petitioners, asserting ownership over a disputed parcel of land based on various Deeds of Absolute Sale.
Factual Summary of the Case
- Myrna L. Hay claimed that the petitioners' father, Pio, sold the property to Haru Gen Beach Resort and Hotel Corporation on November 12, 1988, and that this property was later sold to her on March 5, 1992.
- Myrna also presented a Deed of Absolute Sale, suggesting that Pio sold the same property to her on May 28, 1997.
- The petitioners countered by asserting that Myrna's deeds were falsified, claiming forgery of their father's signature.
- The initial proceedings were characterized by multiple postponements, leading