Alpine Lending Investors v. Corpuz
REITERATIONFacts
The Antecedents: Respondent Estrella Corpuz filed a complaint for replevin against Zenaida Lipata and petitioner Alpine Lending Investors (Alpine). Corpuz alleged that Lipata, pretending to help her secure a Garage Franchise, took her vehicle's registration papers. Lipata then used these papers to retrieve the vehicle from a repair shop and disappeared with it. Corpuz later discovered that Lipata had mortgaged the vehicle with Alpine, using Corpuz's forged signature on the chattel mortgage contract. Corpuz demanded the return of her vehicle from Alpine, but Alpine refused, conditioning its release on Lipata being criminally charged. Procedural History: Corpuz subsequently filed falsification and estafa complaints against Lipata, leading to a warrant for Lipata's arrest. Despite informing Alpine of these developments, the company still refused to return the vehicle. Alpine filed a motion to dismiss the replevin case, arguing it was not a juridical person and thus not a proper party. The Regional Trial Court (RTC) denied this motion. Alpine's motion for reconsideration was also denied, and the RTC directed Corpuz to file an amended complaint. Corpuz filed her amended complaint two days late, but the RTC admitted it. Alpine's subsequent motion to expunge the amended complaint, and its motion for reconsideration, were both denied by the RTC. The Petition: Petitioners Alpine Lending Investors and Rogelio L. Ong filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the RTC's Order dated December 13, 2002, which admitted respondent's amended complaint. They argue that the trial court erred in admitting the amended complaint, despite it being filed late. The core issue presented to the Supreme Court is whether the trial court committed an error in admitting the respondent's amended complaint.
Issue(s)
Whether the trial court erred in admitting respondent's amended complaint. Whether a motion to dismiss constitutes a responsive pleading under Section 2, Rule 10 of the Rules of Civil Procedure.
Ruling
The petition is DENIED. The challenged Order of the RTC, Branch 121, Caloocan City dated December 13, 2002, in Civil Case No. C-20124 is AFFIRMED. Costs against petitioners.
Ratio Decidendi
On the issue of admitting the amended complaint: The Court held that the trial court did not err in admitting the respondent's amended complaint. Under Section 2, Rule 10 of the 1997 Rules of Civil Procedure, a party may amend their pleading once as a matter of right at any time before a responsive pleading is served. The Court emphasized that it is the trial court's correlative duty to accept such an amended complaint, and failure to do so would warrant a writ of mandamus. The admission of the amended complaint was therefore a purely ministerial duty of the trial court. The Court reiterated its policy of being liberal in allowing amendments to pleadings to ensure that the actual merits of a controversy are determined without undue delay and technicalities. The subsequent filing of a motion to admit the amended complaint, even if late, did not divest the respondent of her right to amend, and the trial court's admission of it was in line with the policy of speedy determination of cases on their merits. On the issue of whether a motion to dismiss constitutes a responsive pleading: In this case, petitioner Alpine filed a motion to dismiss, which is not considered a responsive pleading for the purpose of Section 2, Rule 10. Since no responsive pleading had been filed, the respondent had the right to amend her complaint.
Main Doctrine
A motion to dismiss is not a responsive pleading for purposes of Section 2, Rule 10 of the Rules of Civil Procedure. Therefore, a party may amend their complaint as a matter of right before a responsive pleading is served, and the trial court has a ministerial duty to admit such amended complaint.