Superclean Services Corp. vs. CA

G.R. No. 107824 (July 5, 1996)

Facts:

On November 8, 1989, Superclean Services Corporation (petitioner) filed a complaint for Mandamus/Certiorari with a request for a Preliminary Injunction and/or Restraining Order against the Home Development Mutual Fund (private respondent) in the Regional Trial Court of Manila. The petitioner claimed that it was the "lowest or best bidder" for janitorial services for the year 1990, but the private respondent unjustly refused to award the contract and instead published a Notice of Rebidding scheduled for November 9, 1989.

In response, the private respondent argued that none of the bids submitted complied with the terms and conditions established during the pre-bidding conference held on September 6, 1989. The trial court initially set a hearing for the petitioner's application for a preliminary injunction and ordered the private respondent to refrain from conducting the rebidding. The court also allowed the private respondent to hire janitorial services on a month-to-month basis to maintain its offices.

On July 24, 1991, the petitioner sought to file a "Supplemental Complaint," arguing that the delay in the case had rendered the original relief moot and that it was entitled to damages for unrealized profits, exemplary damages, and attorney's fees. The trial court denied this motion, stating that it would substantially change the issues and prejudice the rights of the private respondent. The petitioner’s motion for reconsideration was also denied.

The petitioner subsequently filed a petition for certiorari with the Court of Appeals, which upheld the trial court's decision, stating that the relief sought in the "Supplemental Complaint" was different from the original complaint and that the original complaint had become moot due to supervening events.

Legal Issues:

1. Was the trial court correct in denying the admission of the "Supplemental Complaint" filed by the petitioner?
2. Did the change in the relief sought by the petitioner constitute a change in the theory of the case?
3. Was the original complaint rendered moot and academic, and did this affect the petitioner's ability to seek damages?

Arguments:

• Petitioner’s Arguments:

  • The delay in the resolution of the case rendered the original relief (mandamus) impossible to attain, thus justifying the filing of a "Supplemental Complaint" to seek damages instead.
  • The relief sought in the "Supplemental Complaint" was an alternative remedy that did not change the cause of action but merely adjusted the relief due to supervening events.
  • The admission of the "Supplemental Complaint" would not prejudice the rights of the private respondent, as they would still have the opportunity to respond and present evidence.

• Private Respondent’s Arguments:

  • The trial court correctly denied the "Supplemental Complaint" because it introduced a new relief that was different from the original complaint, thereby changing the issues of the case.
  • Allowing the "Supplemental Complaint" would unfairly prejudice the rights of the private respondent, as it would alter the nature of the case and the defenses available to them.

Court’s Decision and Legal Reasoning:

The Supreme Court reversed the decision of the Court of Appeals and remanded the case to the trial court with instructions to admit the "Supplemental Complaint" and treat it as an amendment to the original complaint. The Court reasoned that:

1. The "Supplemental Complaint" was essentially an amendment to the original complaint, as it sought to change the relief due to the supervening event of the contract year expiring without resolution.
2. The change in relief did not alter the theory of the case, as both complaints were based on the same fundamental issue: the private respondent's unjust refusal to award the contract to the petitioner.
3. The original complaint had not become moot; rather, the specific prayer for mandamus was rendered impossible due to the passage of time. The petitioner still had a viable claim for damages, which could be pursued.
4. The Court emphasized that amendments to pleadings should be liberally construed to allow for the complete determination of the real matter in dispute, and that the admission or rejection of pleadings is within the discretion of the trial court.

Significant Legal Principles Established:

• A "Supplemental Complaint" may be treated as an amendment to the original complaint when it seeks to adjust the relief due to supervening events, provided that the cause of action remains the same.
• Changes in the relief sought do not necessarily constitute a change in the theory of the case, as long as the fundamental issues remain unchanged.
• Courts should favor amendments to pleadings to ensure that all matters in dispute can be resolved in a single proceeding, avoiding multiplicity of actions.