### Facts:
Estrella Corpuz, the respondent, found herself in a dilemma when her former neighbor, Zenaida Lipata, deceitfully obtained the original registration papers of Corpuz’s Toyota Tamaraw FX. Lipata, pretending to assist in securing a Garage Franchise from the Land Transportation Office (LTO), used these documents to misrepresent herself as the vehicle’s owner, extracted the car from Richmond Auto Center where it was being repaired, and subsequently vanished. Corpuz, upon discovering this breach, reported to LTO Muntinlupa City Branch, only to learn her vehicle had been mortgaged to Alpine Lending Investors (Alpine) using a Chattel Mortgage Contract bearing her forged signature. Despite informing Alpine of the forgery and demanding her vehicle’s return, Alpine conditioned its compliance on pressing criminal charges against Lipata.
Corpuz proceeded with Alpine’s condition by filing complaints for falsification of private document and estafa against Lipata in the Metropolitan Trial Court of Caloocan City, leading to an arrest warrant issuance. Despite being updated, Alpine refrained from returning the vehicle. In response, Corpuz initiated a complaint for replevin against Alpine and Lipata in the Regional Trial Court (RTC), Branch 121, Caloocan City, under Civil Case No. C-20124. Alpine contested through a motion to dismiss, claiming it wasn’t a proper party since it wasn’t a juridical person. The RTC rejected this motion and, following Alpine’s unsuccessful reconsideration plea, permitted Corpuz to file an amended complaint. Despite submitting the amended complaint late, the RTC accepted it, leading Alpine to challenge this acceptance on procedural grounds, which failed both initially and on reconsideration.
### Issues:
1. Whether the RTC erred in admitting respondent’s amended complaint.
### Court’s Decision:
The Supreme Court upheld the RTC’s decision to admit the amended complaint, referencing Rules of Civil Procedure that allow amendments to pleadings to ensure that actual merits of controversies are speedily and expeditiously determined without focusing on technicalities. As Alpine’s motion to dismiss did not constitute a responsive pleading under Section 2, Rule 10, Corpuz had the right to amend her complaint as a matter of right, making the RTC’s admission of the amended complaint purely ministerial. Therefore, the petition was denied, affirming the challenged order of the RTC.
### Doctrine:
The court established or reiterated the doctrine that amendments to pleadings are liberally allowed to ensure cases are decided on the merits, not technicalities. A motion to dismiss is not considered a responsive pleading for the purpose of barring amendments to the pleadings.
### Class Notes:
– **Amendments to Pleadings**: The Supreme Court emphasizes the liberal approach towards permitting amendments to pleadings so that the real controversies are adjudicated on their merits rather than on procedural technicalities.
– **Responsive Pleading and Amendment as a Matter of Right**: Under the 1997 Rules of Civil Procedure, Section 2, Rule 10, a party may amend their pleading once as a matter of right before a responsive pleading is served. A motion to dismiss is not considered a responsive pleading.
– **Duty of the Court Regarding Amendments**: The court’s duty to admit an amended complaint is described as purely ministerial when the amendment is made as a matter of right.
### Historical Background:
This case provides a concrete example of the Philippine judiciary’s inclination towards resolving cases based on their substantive merits rather than on procedural technicalities. It demonstrates the judiciary’s effort to foster a legal environment where the focus is on the accurate dispensation of justice, ensuring that parties are not unduly disadvantaged by procedural missteps. This stance is particularly significant in the Philippines, where legal processes can be complex and daunting for the uninitiated, underscoring the courts’ role in ensuring fair and equitable access to justice for all parties involved.
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