Bona fide amendments to pleadings are allowed at any stage of the proceedings so that every case may as much as possible, be determined on its real facts, affording complete relief to all the parties involved in the case.[1] Thus, as a matter of judicial policy, courts are impelled to treat motions for leave to file amended pleadings with liberality, the paramount consideration being that it does not appear that the motion for leave was with intent to delay the proceedings.
It is undisputed that petitioners filed their original Answer back in August 26, 2016, and they sought its amendment only after the trial court had concluded the pre-trial conference, wherein "[t]he necessity or desirability of amendments to the pleadings"[38] should have been considered. Aptly so, petitioners moved for leave of court to admit their Amended Answer, recognizing that its filing was no longer a matter of right, but subject to the trial court's discretion.[39] In the exercise of such discretion, trial courts may grant leave and allow the filing of an amended pleading so long as it does not appear that the motion for leave was made in bad faith or with intent to delay the proceedings.[40]
Apropos are Sections 1[41] and 3,[42] Rule 10 of the Rules of Court, which allow amendments to pleadings "by adding [to] or striking out an x x x inadequate allegation or description in any other respect, so that the actual merits of the controversy may speedily be determined, without regard to technicalities, and in the most expeditious and inexpensive manner."
The only limitation under the rules was that the leave to amend the pleading "may be refused if it appears to the court that the motion was made with intent to delay."
Thus, "[a]s a matter of judicial policy, courts are impelled to treat motions for leave to file amended pleadings with liberality[,]"[43] especially when such motion "is filed during the early stages of [the] proceedings or, at least, before trial."[44]
Remedial Law: Excerpts of the 2019 Amendments to the 1997 Rules of Civil Procedure (2022) by Mogello
In sum, we find that the RTC gravely abused its discretion in denying the Motion for Leave on the ground that the case had already gone through preliminary/pre-trial conference.
The attendant circumstances demonstrate that the RTC had no cause to deny the leave sought for the admission of petitioners' Amended Answer. Rather, its grant would be in keeping with the time-honored judicial policy of favoring and affording liberal treatment to amendments to pleadings, especially those made before the conduct of the trial[56] as in this case. In this regard, we reiterate the Court's constant reminder:
“We should always bear in mind that rules of procedure are mere tools designed to facilitate the attainment of justice. Their strict and rigid application especially on technical matters, which tends to frustrate rather than promote substantial justice, must be avoided. Technicality, when it deserts its proper office as an aid to justice and becomes its great hindrance and chief enemy, deserves scant consideration from the courts.”[57]
HEIRS OF PIO TEJADA et al vs. HAY et al, G.R. No. 250542, October 10, 2022
LOPEZ, M., J.
FOOTNOTES
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