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Heirs of Tejada v. Hay (GR No. 250542, 10 October 2022)

The case involved a complaint to quiet title filed by Myrna against the Heirs of Tejada. After preliminary proceedings, the heirs filed a motion for leave to file an amended answer. The trial court denied the motion. The Supreme Court ruled that the amended answer should be admitted since it was intended to clarify issues and expedite the case, not cause delay.

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14 views1 page

Heirs of Tejada v. Hay (GR No. 250542, 10 October 2022)

The case involved a complaint to quiet title filed by Myrna against the Heirs of Tejada. After preliminary proceedings, the heirs filed a motion for leave to file an amended answer. The trial court denied the motion. The Supreme Court ruled that the amended answer should be admitted since it was intended to clarify issues and expedite the case, not cause delay.

Uploaded by

Patrick Chad Guzman
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Heirs of Pio Tejada and Soledad Tejada, represented by Pio Domingo Tejada vs.

Garry
B. Hay, in substitution of Myrna L. Hay, represented by his Attorney-in-Fact
Gomercindo Litong
G.R. No. 250542, October 10, 2022
(Justice Mario V. Lopez)

FACTS:

Myrna filed a Complaint for Quieting of Title against the Heirs of Tejada (Heirs). The
heirs filed their Answer. Accordingly, the case went through preliminary and pre-trial
conference and a pre-trial order was issued by the RTC.

After the preliminary/pre-trial conference, but before trial, the heirs filed a Motion for
Leave for their Amended Answer to be admitted (Motion for Leave) for the purpose of
"clarifying several matters and to hasten the determination of the actual merits of the
controversy."

The Motion also stated that the leave sought and amendments made were not dilatory,
but will aid the court to resolve the case speedily and based on its real facts.

The RTC denied the Motion for Leave on the ground that the case had already gone
through preliminary/pre-trial conference (without determining whether the Motion for
Leave was interposed only to delay the proceedings).

MAY THE AMENDED ANSWER BE ADMITTED CONSIDERING THAT THE CASE


HAD ALREADY GONE THROUGH PRELIMINARY/PRE-TRIAL CONFERENCE?

Yes.

In furtherance of justice, amendments to pleadings are favored and should be liberally


allowed at any stage of the lawsuit as long as they are not dilatory. Here, the Amended
Answer sought to be admitted is not dilatory because it is intended to aid the court in
determining the real controversies for resolution and thereby expedite the proceedings.
There is no showing that the Motion for Leave was filed as a dilatory tactic. In fact, the
RTC did not even determine whether the Motion for Leave was interposed only to delay
the proceedings. Hence, the Amended Answer may be admitted.

"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."

"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. 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."

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