had fraudulently obtained a certificate of title over the same property in the

Had fraudulently obtained a certificate of title over

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Paranaque City, discovered that a certain Rolando Mojica, Jr. had fraudulently obtained a certificate of title over the same property in the latter’s name. Aguinaldo filed a complaint for the nullification of the title with the RTC against Mojica, likewise causing the annotation of a notice of lis pendens in the said title. The RTC nullified Mojica’s title but before Aguinaldo discovered Mojica’s title, Mojica had already executed a real estate mortgage over the property in favor of Citystate Savings Bank, Inc. as a security for a loan. When Mojica was unable to pay the said loan, Citystate extrajudicially foreclosed the property and was declared the highest bidder in the public auction. Consequently, Citystate consolidated its title over the subject property and a new TCT was issued in its favor. Aguinaldo filed a complaint for annulment of title with the RTC against Citystate. In its answer, Citystate asserted that it was the real and registered owner of the property. After the parties have presented their respective evidence, but before the presentation of rebuttal evidence, Aguinaldo filed a Motion to Admit Amended Complaint before the court. He alleged that Citystate was able to secure a writ of possession during the pendency of the case, thereby evicting Aguinaldo from the
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REMEDIAL LAW (RECENT JURISPRUDENCE 2015) Dean’s Circle 2016 19 subject property. He also claimed that Citystate further sold the property to Syndica Phil. Corporation. The RTC denied Aguinaldo’s motion on the ground that the amendments substantially altered the cause of action which woul d result in delay of the case’s resolution. The CA reversed the RTC’s ruling. Issue: Whether a proposed amended complaint may be admitted. Ruling: YES. Granting arguendo that the amendment of the complaint would substantially alter or change the cause of action or defense in said controversy, this Court nonetheless holds that in the higher interest of substantial justice, the introduction of amendments to the complaint is apropos at this particular instance to forestall further delay in the resolution of the actual merits of the parties' respective claims and defenses. To reiterate, the Rules of Court seek to eliminate undue reliance on technical rules and to make litigation as inexpensive, as practicable and as convenient as can be done. Rules of procedure, after all, are but tools designed to facilitate the attainment of justice, such that when rigid application of the rules tends to frustrate rather than promote substantial justice, the Supreme Court is empowered to suspend their operation. This Court will not hesitate to set aside technicalities in favor of what is fair and just. In this case, the CA allowed the amended complaint in order to grant complete relief to Aguinaldo. The additional reliefs being sought in the amended complaint does not alter Aguinaldo's cause of action or the theory of case. These are mere remedies to which Aguinaldo became entitled to as a result of the alleged supervening events, which rendered the relief being sought in the original complaint inadequate. The Court notes that when the instant case was instituted, Aguinaldo's prayer
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