Garcia, Jr. v. Ranada Jr.
REITERATIONFacts
1. The Antecedents: Private respondent State Investment House, Inc. (SIHI) filed a complaint for collection of sums of money with attachment against Western Minolco Corporation (WESCOR) and petitioner Antonio Garcia, Jr. Garcia, as president of WESCOR, had co-signed a Comprehensive Surety Agreement, jointly and severally undertaking to pay SIHI up to P4,000,000.00 for credit accommodations extended to WESCOR. 2. Procedural History: Petitioner filed an original answer on March 31, 1978. Approximately two years and seven months later, after the plaintiff had rested its case, petitioner filed a motion to amend his answer. The trial court initially granted this motion on January 15, 1981. However, upon motion for reconsideration by the private respondent, the trial court set aside its previous order and struck the amended answer from the records on April 1, 1981. Petitioner then filed a special civil action for certiorari with the Court of Appeals, alleging grave abuse of discretion by the trial judge. The Court of Appeals dismissed the certiorari action, deeming the trial court's action an error of judgment correctible only by appeal and not by certiorari, and also noting the premature filing of the petition. 3. The Petition: Petitioner seeks review on certiorari of the Court of Appeals' decision. The core issue is whether the trial court's disallowance of the amended answer constitutes a grave abuse of discretion correctible by certiorari. Petitioner argues that the amendment was necessary to fully present the merits of the controversy and that its disallowance was an abuse of discretion. The petition contends that the Court of Appeals erred in dismissing the certiorari action, asserting that the trial court's action was indeed a grave abuse of discretion.
Issue(s)
Whether the trial court's disallowance of petitioner's amended answer constitutes grave abuse of discretion correctible by a writ of certiorari. Whether the Court of Appeals erred in dismissing the petition for certiorari.
Ruling
The Supreme Court affirmed the judgment of the Court of Appeals, holding that the disallowance of the amended answer did not constitute grave abuse of discretion and that certiorari was not the proper remedy.
Ratio Decidendi
On the propriety of certiorari and the trial court's discretion: The Court reiterated that certiorari is limited to correcting jurisdictional defects, not mere errors of judgment. The discretion to allow or disallow amendments is a matter of judgment, correctible by appeal unless amounting to grave abuse. The amended answer was filed belatedly, after the plaintiff rested, and would substantially alter the defense and cause delay, justifying the trial court's disallowance. This was a proper exercise of discretion, not grave abuse. On the dismissal of the petition for certiorari: The Court agreed that admitting the amended answer would necessitate re-opening the plaintiff's case, delaying proceedings. The claim of a failure to express true intent invokes the parole evidence rule, requiring extrinsic evidence. Such a late and substantial alteration, coupled with potential delay, justified the refusal. Even if erroneous, the disallowance was a mere error of judgment, not meeting the stringent threshold for certiorari. The petition was also prematurely filed without a motion for reconsideration, failing to give the judge an opportunity to correct himself. The Court reiterated the policy of liberality in amendments decreases as the case progresses, and late amendments altering the defense may be refused. The circumstances here fell outside liberal allowance.
Main Doctrine
The disallowance of a belatedly filed amended answer that substantially alters the defense and would occasion delay, especially after the plaintiff has rested its case, does not constitute grave abuse of discretion correctible by certiorari, as it is a mere error of judgment, not of jurisdiction.