Superclean Services Corporation v. Court of Appeals and Home Development Mutual Fund
REITERATIONFacts
The Antecedents: Petitioner Superclean Services Corporation filed a complaint for Mandamus/Certiorari with Preliminary Injunction against respondent Home Development Mutual Fund (HDMF), alleging it was the lowest or best bidder for janitorial services for 1990, but HDMF refused to award the contract and instead published a notice of rebidding. HDMF defended its action by stating that no bid complied with the terms and conditions. Procedural History: The trial court ordered HDMF to desist from rebidding but allowed it to hire janitorial services on a month-to-month basis. Petitioner later filed a "Supplemental Complaint," seeking damages (unrealized profits, exemplary damages, attorney's fees) because the contract period for 1990 had passed, rendering its original prayer for mandamus moot and academic. The trial court denied the motion to admit the supplemental complaint, finding it would radically change the issues and prejudice HDMF. The Court of Appeals affirmed the trial court's decision, holding that the supplemental complaint sought a different relief and that supplemental pleadings are meant to aid, not substitute, the original pleading. The appellate court also found the original complaint moot and academic. The Petition: Petitioner seeks review of the Court of Appeals' decision, arguing that the trial court erred in denying the admission of its "Supplemental Complaint."
Issue(s)
Whether the filing of a "Supplemental Complaint" to seek a different relief due to supervening events is proper. Whether an amendment to change the relief sought, necessitated by supervening events, changes the cause of action or theory of the case. Whether the original action for mandamus and injunction had become moot and academic, precluding supplementation.
Ruling
The Supreme Court reversed the decision of the Court of Appeals. The case was remanded to the trial court with instructions to admit the "Supplemental Complaint" and treat it as an amendment to the original complaint, or to require petitioner to file an amended complaint, merging the allegations of both, and thereafter allow private respondent to file an answer.
Ratio Decidendi
On the propriety of a "Supplemental Complaint" for a different relief: The Court clarified that a supplemental pleading, under Rule 10, Section 6 of the Rules of Court, is intended to set forth transactions or events that have happened since the date of the pleading sought to be supplemented, and must be in aid of the original pleading. In this case, the supervening event (the passage of the contract year) was not invoked to aid the original demand for the contract award but to justify a new relief (damages) because the original relief became impossible. Therefore, the proper remedy was not to supplement but to amend the complaint. The Court stated that the "Supplemental Complaint" should be treated as embodying amendments to the original complaint or petitioner could be required to file an amended complaint. On whether changing the relief changes the cause of action or theory of the case: The Court held that an amendment to change the relief sought does not change the theory of the case, as long as the cause of action remains the same. The prohibition is against changing the cause of action. The Court cited Arches v. Villarruz and Vda. de Villaruel v. Manila Motor Co., Inc. to support the principle that amendments should be favored in furtherance of justice to thresh out the real question between the parties. In this case, the cause of action for both the original complaint (mandamus and injunction) and the proposed amendment (damages) was the same: private respondent's unjustified refusal to award the contract to petitioner. The change in relief was necessitated by a supervening event, not a change in the underlying wrong. On the mootness of the original action: The Court disagreed with the Court of Appeals' conclusion that the action had become moot and academic, thus precluding supplementation. While the prayer for mandamus might have become moot due to the passage of time, the underlying cause of action and the alternative remedy of seeking damages remained. The Court likened the situation to an illegal dismissal case where reinstatement may be impossible, but separation pay can still be claimed. The Court emphasized that the basic allegations of fact remained the same and that requiring a new complaint would exalt technicality over substance. The "Supplemental Complaint" should be considered as amendments to the original complaint to serve the interests of justice.
Main Doctrine
A supplemental pleading is proper to set forth events that have happened since the date of the pleading sought to be supplemented, but it must be in aid of the original pleading, not to entirely substitute it. If a supervening event renders the original relief impossible and justifies a new relief, an amendment to the complaint, not a supplemental complaint, is the proper remedy, provided it does not change the cause of action.