Camcam v. Vazquez
REITERATIONFacts
The Antecedents: Edna G. de Camcam (Camcam) and Benjamin M. Bitanga (Bitanga) filed a complaint for reconveyance, alleging that Camcam owned a property mortgaged to UCPB. Following foreclosure and a compromise settlement allowing redemption, Bitanga acted as trustee to redeem the property. Camcam then borrowed P16 Million from Daniel E. Vazquez (Vazquez), securing the loan with the property through a Sale with Right of Repurchase executed by Bitanga. Camcam claims she fully repaid Vazquez in 1996. In 2012, Vazquez demanded Camcam vacate the property, which Camcam refused, asserting the sale was an equitable mortgage, the loan was repaid, and the transfer of title was void. Procedural History: Camcam and Bitanga filed a complaint with the RTC of Makati City. Vazquez moved for summary judgment, which the RTC granted, dismissing the complaint. The RTC found no genuine issue of material fact, deeming Vazquez the owner based on admitted facts and documentary evidence. Petitioners' motion for reconsideration was denied. They appealed to the Court of Appeals (CA), arguing the disposition was premature and genuine issues necessitated a full trial. The CA affirmed the RTC's decision. Separately, the RTC initially denied petitioners' motion to amend their complaint, but this was reversed by the CA in a prior petition (CA-G.R. SP No. 129738), which directed the RTC to admit the amended complaint and try the case. This CA decision was affirmed by the Supreme Court. The Petition: This Petition for Review on Certiorari assails the CA's Decision and Resolution affirming the RTC's grant of summary judgment. Petitioners argue that a supervening event—the allowance of their amended complaint by a higher court—should have rendered the summary judgment moot. They further contend that genuine issues of fact remain, requiring a full-blown trial. The Supreme Court, in its ruling, found merit in the petition, noting that the amended complaint supersedes the original one, rendering the summary judgment and its affirmation by the CA invalid. The Court remanded the case to the RTC for proceedings based on the amended complaint.
Issue(s)
Whether the Court of Appeals erred in affirming the grant of Summary Judgment despite the final order to admit the petitioners' Amended Complaint, thereby failing to recognize the amended complaint's superseding effect on the original complaint and the consequent invalidity of the summary judgment based on the superseded pleading.
Ruling
The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Court of Appeals' Decision and Resolution, and REMANDED the case to the Regional Trial Court for further proceedings.
Ratio Decidendi
On the Issue of Summary Judgment and Amended Complaints: The Supreme Court ruled that the petition had merit because the supervening admission of the amended complaint fundamentally altered the procedural landscape of the case. Applying the rule in Philamlife v. Hon. Breva, the Court emphasized that under Section 8, Rule 10 of the Rules of Civil Procedure, an amended complaint supersedes the original complaint. Since the Court of Appeals in CA-G.R. SP No. 129738 (affirmed by the Supreme Court in G.R. No. 216657) had already ordered the RTC to admit the amended complaint and try the case, the original complaint was legally replaced. Consequently, the Motion for Summary Judgment and the resulting RTC Resolution had no legal leg to stand on, as they were both predicated on a pleading that had been superseded. The Court reasoned that a summary judgment cannot be maintained when the very foundation of the dispute—the complaint—has been substituted by an amended version that requires a new assessment of genuine issues. Therefore, the Court found it necessary to remand the case to the RTC to proceed based on the amended complaint to ensure the resolution of the actual merits of the parties' claims.
Main Doctrine
Under the 1997 Revised Rules of Civil Procedure, specifically Section 8, Rule 10, an amended complaint supersedes the original pleading it seeks to amend. This means the original complaint is effectively withdrawn from the record and replaced by the new version. If a trial court renders a summary judgment based on the original complaint while an amendment is subsequently ordered to be admitted by a higher court, the summary judgment becomes legally untenable. The court must remand the case to proceed based on the amended complaint to ensure that the actual merits of the dispute are adjudicated.