Whether or not
the
Year
Case Title supplemental Brief Facts
Decided
pleading is
allowed
1 1990 Shoemart vs CA Supplemental Petitioner filed an ejectment case.
G.R. No. 86956 complaint They later filed a supplemental
allowed complaint asking for damages in
the form of increased rental
amounting to P45,142. The CA
held that the damages to be
awarded is limited to the amount
they asked in the supplemental
complaint and did not consider the
rental increases effected during
the unlawful detainer period
2 1996 Superclean Supplemental Superclean filed a complaint for
Services Corp vs pleading was mandamus to compel HDMF to
CA G.R. no. treated as an award them a contract. Thereafter,
107824 amended they moved for the admission of a
complaint “supplemental complaint” alleging
that because the contract for
services was for the previous year,
the delay in the decision of this
case is rendered moot thus, they
instead pursued a prayer for
damages.
The lower courts denied its
admission on the basis that the
relief sought in the "Supplemental
Complaint" was different from that
contained in the original complaint
which sought to compel private
respondent to recognize petitioner
as the lowest qualifying bidder. In
addition, the appellate court held
that the original complaint had
been rendered moot and academic
by supervening events and that a
supplemental complaint was
inappropriate since "supplemental
Brief Ruling
Contrary to the conclusion of respondent court, petitioner's
recovery is not limited by the amount of P45,142.00 prayed
for in the supplemental complaint as increased rental
effective January 1, 1979. This is not a case of a complaint
subsequently amended, the effect of which is to render the
original complaint abandoned or inexistent and let the
amendment take form as the sole substitute upon which the
case stands for trial. On the other hand, a supplemental
complaint or pleading supplies deficiencies in aid of an
original pleading, not to entirely substitute the latter.
The "Supplemental Complaint" appears to have been filed
under Rule 10 of the Rules of Court which provides: Sec. 6,
Matters Subject of Supplemental Pleadings. — Upon motion
of a party the court may, upon reasonable notice and upon
much terms as are just, permit him to serve a supplemental
pleading setting forth transactions, occurrence of events
which have happened since the date of the pleading sought
to be supplemented. The transaction, occurrence or
event happening since the filing of the pleading, which
is sought to be supplemented, must be pleaded in aid of
a party's right or defense as the case may be. But in the
case at bar, the supervening event is not invoked for
that purpose but to justify the new relief sought. It cited
not to reinforce or aid the original demand, which was for the
execution of a contract in petitioner's favor, but to say that,
precisely because of it, petitioner's demand could no longer
be enforced, thus justifying petitioner in changing the relief
sought to one for recovery of damages. This being the
case, petitioner's remedy was not to supplement, but
rather to amend its complaint. Indeed the new relief
sought (payment of damages in lieu of an award of the
contract for janitorial services) is actually an alternative
remedy to which petitioner was entitled even before at the
time of the filing of its original complaint. Be that as it may,
the so-called Supplemental Complaint filed by petitioner
should simply be treated as embodying amendments to the
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 Whether or not
the
Year
Case Title supplemental Brief Facts Brief Ruling
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pleading is
allowed
original complaint or petitioner may be required to file an
pleadings are meant to supply the amended complaint.
deficiency in aid of the original
pleading, not to entirely substitute
the latter."

3 1999 Caoili vs CA G.R. Supplemental Petitioner’s supplemental motion The rule is well-settled that the admission or non-admission
no. 128325 motion for for reconsideration was denied. of a supplemental pleading is not a matter of right but is
reconsideration They contend that their discretionary on the court. As differentiated from an
was not allowed Supplemental Motion for amended pleading which takes the place of the original
Reconsideration was submitted pleading, a supplemental pleading does not extinguish the
after the main Motion for existence of the original; it only serves to bolster or adds
Reconsideration had been filed something to the primary pleading. A supplement exists side
within the required period and by side with the original; it does not replace that which it
which motion had not yet been supplements; it does not supersede the original but
timely resolved. They argue that assumes that the original pleading is to stand and the issues
had the Supplemental Motion for joined under the original pleading remain as issues to be
Reconsideration been admitted, tried in the action. A supplemental pleading supplies
the meritorious allegations therein deficiencies in aid of an original pleading, not to entirely
would have been given due substitute the latter.
course.
A perusal of the Supplemental Motion for Reconsideration
reveals that the arguments raised by petitioners in the
supplemental motion are matters which have already been
substantially discussed, considered, and passed by the
Court of Appeals in its decision. Thus, even assuming a
grati argumenti that the supplemental motion was admitted
as part of the record, the Court of Appeals would not have
decided otherwise.

4 1999 Trinidad vs Supplemental Petitioner filed a petition for The subject of the supplemental pleading filed by petitioner
COMELEC G.R. petition was correction of manifest errors and was not in accordance with the prescribed rule.
No. 134657 treated as a annulment of the proclamation of
petition for Claudio as Pasay mayor. They As the name connotes, a supplemental petition merely
correction of later filed a supplemental petition supplies deficiencies in aid of the original petition. It cannot

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 Whether or not
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Year
Case Title supplemental Brief Facts Brief Ruling
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allowed
manifestation averring the error in the summary be used to introduce a new matter or a new cause of
was treated as an statement of votes. The action or defense which is precisely what the petitioner
entirely new COMELEC affirmed the had done in the instant case.
petition proclamation despite the issues
raised in the supplemental petition. The issue raised in the Supplemental Petition is a new one,
not even advanced in the original Petition. It sought the
correction of Summary Statement of Votes No. 094338
which credited petitioner with only 1009 votes when
Statement of Votes No. 094284 upon which the former was
based listed 1099 votes for him.

5 2000 Asset Supplemental Respondent corporation filed a When the cause of action stated in the supplemental
Privatization motion not complaint to prevent the DBP from complaint is different from the cause of action mentioned in
Trust vs Court of admitted pursuing the amount of deficiency the original complaint, the court should not admit the
Appeals G.R. No. after an extrajudicial foreclosure supplemental complaint.
81024 sale of the mortgaged vessels. In
the supplemental complaint, what In this case, hardly do the original and supplemental
private respondent SIM seeks to complaints meet the required test of "unity in the problem
preempt is the foreclosure of the presented" and "a common question of law and fact
mortgage of its Agusan del Sur involved" as regards jurisdiction venue and joinder of
plant. parties. The ultimate problem in the original complaint as far
as private respondents are concerned is how to prevent

6 2001 De Rama vs CA Supplemental Petitioner sought to recall the a supplemental pleading must state transactions,
G.R. No. 131136 motion not appointment of 14 municipal occurrences or events which took place since the time the
admitted employees on the ground that the pleading sought to be supplemented was filed. In the instant
appointments were midnight case, petitioner alleged fraud and irregularities that
appointments. The CSC denied supposedly occurred contemporaneous to the execution of
the petition. Before the Court the appointments. They should have been raised at the very
Appeals, petitioner filed a first opportunity. They are not new events which petitioner
supplement to the consolidated could not have originally included as grounds for the recall
appeal where he laid out evidence of the appointments.
showing that the appointments

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 Whether or not
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Year
Case Title supplemental Brief Facts Brief Ruling
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pleading is
allowed
were obtained through fraud.

7 2001 Abella vs CA Supplemental Respondents filed a complaint
G.R. Nos. 10063 & complaint not assailing a memorandum of
101550 admitted agreement as void ab initio.
However, in their supplemental
complaint, they used as basis the
very same memorandum of
agreement to exercise their option
to repurchase. The RTC admitted
the supplemental complaint. The
CA reversed.
We find that Deogracias and Rosalina's "supplemental
complaint" contains matters entirely different from and even
contrary to the cause of action stated in the original
complaint. Hence, we agree with the Court of Appeals that
the trial court should not admit the same.
A pleading subsequently filed after an original one which
states a totally different cause of action is not a
"supplemental pleading" and is not permitted. The rule
allowing amendments to a pleading is subject to the general
limitation that the cause of action shall not be substantially
changed or that the theory of the case shall not be altered.

8 2005 Planters LZK obtained a loan from Planters,
Development secured by a real estate mortgage.
Bank vs LZK LZK defaulted so Planters caused
Holdings and the extrajudicial foreclosure of the
Development property. Planters was the highest
Corporation G.R. bidder. LZK filed a complaint for
No. GR 153777 annulment of extrajudicial
foreclosure, mortgage contract and
promissory notes with RTC Makati.
It then filed a motion to leave to file
a supplemental complaint covering
occurrence subsequent to the
original complaint, including an
alleged agreement to enter a
contract of lease where the
lessees would directly remit their
respective rentals to Planters.
Planters opposed stating that
matters in the supplemental
The purpose of the supplemental pleading is to bring into
the records new facts which will enlarge or change the kind
of relief to which the plaintiff is entitled; hence, any
supplemental facts which further develop the original right of
action, or extend to vary the relief, are available by way of
supplemental complaint even though they themselves
constitute a right of action.
While a matter stated in a supplemental complaint should
have some relation to the cause of action set forth in the
original pleading, the fact that the supplemental pleading
technically states a new cause of action should not be a bar
to its allowance but only a factor can be considered by the
court in the exercise of its discretion; and of course, a broad
definition of "cause of action" should be applied here as
elsewhere
In the present case, the issue as to whether the petitioner
stopped the payment of rentals and the application thereof
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 Whether or not
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Year
Case Title supplemental Brief Facts Brief Ruling
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pleading is
allowed
complaint give rise new causes of on the perceived loan deficiency of the respondent, is a new
action. matter that occurred after the filing of the original complaint.
However, the relief for damages, the collection of the rentals
and the application thereof by the petitioner to the perceived
loan deficiency of the respondent are germane to, and are in
fact, intertwined with the cause of action of nullification of
the real estate mortgage and the extrajudicial foreclosure
thereof, as well as the sale at public auction.
9 2010 Pentacapital Declared Counterclaim was imposed for The alleged obligation of petitioner already existed and was
Investment improper damages, and a supplemental known to respondent at the time of the filing of his Answer
Corporation v. counterclaim was filed to ask for with Counterclaim. He should have demanded payment of
Makilito B. commissions from sales and legal his commission and share in the proceeds of the sale in that
Mahinay interests on the sums demanded. Answer with Compulsory Counterclaim, but he did not. He
G.R. No. 171736 Said counterclaim was filed after is, therefore, proscribed from incorporating the same and
July 5, 2010 the dismissal of an separate and making such demand via a supplemental pleading. The
earlier case. supplemental pleading must be based on matters arising
subsequent to the filing of the original pleading related to the
claim or defense presented therein, and founded on the
same cause of action. Supplemental pleadings must state
transactions, occurrences or events which took place since
the time the pleading sought to be supplemented was filed.

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 Whether or not
the
Year
Case Title supplemental Brief Facts Brief Ruling
Decided
pleading is
allowed
10 2012 Lilia V. Ada v. Allowed Initial complaint was for partition of In Planters Development Bank v. LZK Holdings and
Florante Baylon an estate, and a supplemental Development Corp., we clarified that, while a matter stated
GR No. 182435, complaint for rescission of a in a supplemental complaint should have some relation to
Aug 13, 2012 donation of a property which was the cause of action set forth in the original pleading, the fact
supposedly part of the estate was that the supplemental pleading technically states a new
filed. cause of action should not be a bar to its allowance but only
a matter that may be considered by the court in the exercise
of its discretion. In such cases, we stressed that a broad
definition of "cause of action" should be applied.

11 2014 Marichu G. Ejera Not directly ruled Petitioner filed a supplemental The petitioner insists that the RTC erroneously resolved
v. Beau Henry L. upon complaint, to implead an additional Paltinca's motion to dismiss without first admitting her
Mierto and Merto defendant. Case was dismissed by supplemental pleading.
and Erwin the RTC on motion by the
Vergara respondent, before ruling that the The insistence is not correct. The petitioner filed her
G.R. No. 163109, supplemental complaint was supplemental complaint to assail Office Order No. 005, and
January 22, 2014 admitted. Petitioner avers that thereby raised issues identical to those raised in her original
there should have been an order complaint involving Office Order No. 008. Hence, the RTC
first admitting the supplemental could already resolve Paltinca's motion to dismiss even
complaint before the motion to without first admitting the supplemental complaint. Unlike an
dismiss could have been ruled amended complaint, her supplemental complaint could
upon. "exist side-by-side" with the original complaint, because the
supplemental complaint averred facts supervening from the
filing of the complaint. Rule 10 of the 1997 Rules of Civil
Procedure expressly provides:

Section 6. Supplemental pleadings. — Upon motion of a

party the court may, upon reasonable notice and upon such
terms as are just, permit him to serve a supplemental
pleading setting forth transactions, occurrences or events
which have happened since the date of the pleading sought
to be supplemented. The adverse party may plead thereto
within ten (10) days from notice of the order admitting the
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 Whether or not
the
Year
Case Title supplemental Brief Facts Brief Ruling
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pleading is
allowed
supplemental pleading.

12 2015 Ortigas & Co. Allowed Petition filed a petition for The supplemental pleading was allowed which contained
Limited Reconstitution of TCT. allegations of the respondent in support of its opposition.
Partnership v. Respondent filed an opposition to [NOT RULED UPON BY SC]
Velasco this and subsequently filed a
G.R. No. 109645, supplemental pleading.
112564, 128422,
128911
January 21, 2015

13 2015 Republic v. Allowed Petition for review on certiorari
Karbasi was filed assailing the decision of
G.R. No. 210412 the CA, which affirmed the grant of
July 29, 2015 naturalization to Karbasi. Karbasi
filed a comment on the petition on
April 7, 2014 and moved for leave
of court to file a supplemental
pleading on September 18, 2014
The supplemental pleading was allowed by the Court in
which Karbasi insisted that pursuant to the 1951 Convention
Relating to the Status of Refugees and the 1967 Protocol
Relating to the Status of Refugees, to which the Philippines
was a signatory, the country was bound to safeguard the
rights and well-being of the refugees and to ensure the
facility of their local integration including naturalization.
[NOT RULED UPON BY SC]

14 2017 Central Bank Denied Respondent filed a complaint for A supplemental pleading only serves to bolster or add
Board of the propriety of the liquidation and something to the primary pleading. Its usual function is to
Liquidators v. 10 years after filed a motion to set up new facts that justify, enlarge, or change the kind of
Banco Filipino admit amended/supplemental relief sought with respect to the same subject matter as that
Savings and complaint. of the original complaint.
Mortgage Bank
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 Whether or not
the
Year
Case Title supplemental Brief Facts Brief Ruling
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pleading is
allowed
G.R. No. 173399 This Court ruled in Leobrera v. CA that a supplemental
February 21, 2017 complaint must be founded on the same cause of action as
that raised in the original complaint. Although in Planters
Development Bank v. LZK Holdings & Development
Corporation, the Court clarified that the fact that a
supplemental pleading technically states a new cause of
action should not be a bar to its allowance, still, the matter
stated in the supplemental complaint must have a relation to
the cause of action set forth in the original pleading. That is,
the matter must be germane and intertwined with the cause
of action stated in the original complaint so that the principal
and core issues raised by the parties in their original
pleadings remain the same.

In the instant case, Banco Filipino, through the Second

Amended/Supplemental Complaint, attempted to raise new
and different causes of action that arose only in 1994. These
causes of action had no relation whatsoever to the causes
of action in the original Complaint, as they involved different
acts or omissions, transactions, and parties.