Bautista v. Maya-Maya Cottages, Inc.
REITERATIONFacts
1. The Antecedents: Spouses Rafael and Ligaya Bautista are the registered owners of a 3,856-square meter lot in Nasugbu, Batangas, evidenced by Original Certificate of Title (OCT) No. P-1436 issued on January 15, 1989. Maya-Maya Cottages, Inc. (MMCI) filed a complaint against the Bautistas, alleging that they obtained the title through dubious means and without color of right. MMCI sought the cancellation of the Bautistas' title and damages, along with a preliminary injunction. 2. Procedural History: The Bautistas moved to dismiss MMCI's complaint, arguing that MMCI, as a private corporation, is constitutionally disqualified from acquiring alienable public lands except by lease, thus lacking a cause of action. The Regional Trial Court (RTC) initially granted this motion. However, upon MMCI's motion for reconsideration and leave to file an amended complaint, alleging that the technical description in the Bautistas' title did not cover the disputed lot, the RTC reversed its earlier order and denied the motion to dismiss. The Bautistas then filed a special civil action for certiorari and prohibition with the Court of Appeals, asserting that the amended complaint did not cure the original defect and that the RTC gravely abused its discretion. The Court of Appeals dismissed this petition, and a subsequent motion for reconsideration was denied. 3. The Petition: The Bautistas filed the instant petition for review on certiorari under Rule 45 of the Rules of Court, seeking to overturn the Court of Appeals' decision. They argue that the Court of Appeals erred in holding that the trial court did not commit grave abuse of discretion in admitting MMCI's amended complaint. The core of their argument is that a motion to dismiss is not a responsive pleading, and therefore, MMCI had an absolute right to amend its complaint before a responsive pleading was filed, as provided by Section 2, Rule 10 of the Rules of Civil Procedure. The petition also raises the issue of MMCI's alleged disqualification from acquiring the land, which the Court of Appeals deemed a matter for full trial.
Issue(s)
Whether the Court of Appeals erred in holding that the trial court did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in admitting respondent’s amended complaint. Whether respondent corporation is barred from acquiring the subject lot.
Ruling
The petition is DENIED. The challenged Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 43574 are AFFIRMED IN TOTO. Costs against petitioners.
Ratio Decidendi
On the issue of admitting the amended complaint: The Court affirmed the Court of Appeals' ruling that the trial court did not commit grave abuse of discretion. Section 2, Rule 10 of the 1997 Rules of Civil Procedure, as amended, clearly provides that a party may amend its pleading once as a matter of right at any time before a responsive pleading is served. A motion to dismiss is not considered a responsive pleading under this rule. Therefore, the respondent had an absolute right to amend its complaint before any responsive pleading was filed. The records showed that petitioners had not yet filed a responsive pleading, but rather a motion to dismiss. Consequently, the respondent, as plaintiff, could file an amended complaint even after the original complaint was ordered dismissed, provided the order of dismissal was not yet final. The Court of Appeals correctly held that the trial court did not gravely abuse its discretion in admitting the amended complaint, and thus, neither certiorari nor prohibition would lie. On the issue of respondent corporation's capacity to acquire the lot: The Court held that this contention is a matter of defense that can only be properly determined during a full-blown trial of the case. It is not an issue that can be resolved in a petition for certiorari concerning the admission of an amended complaint.
Main Doctrine
A motion to dismiss is not considered a responsive pleading under Section 2, Rule 10 of the 1997 Rules of Civil Procedure, as amended. Therefore, a party has an absolute right to amend its pleading once as a matter of right before a responsive pleading is served.