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IN MATTER OF HEIRSHIP OF LATE HERMOGENES RODRIGUEZ v. JAIME M. ROBLES

FACTS:

On September 14, 1989, a petition for Declaration of Heirship and Appointment of Administrator and Settlement of the Estates of the Late Hermogenes Rodriguez and Antonio Rodriguez was filed before the Regional Trial Court (RTC) of Iriga City. The petition was filed by Henry F. Rodriguez, Certeza F. Rodriguez, and Rosalina R. Pellosis, who sought to be declared as the sole and surviving heirs of Antonio and Hermogenes Rodriguez. They claimed to be the great-grandchildren of Antonio and alleged their lineage based on a genealogy.

At the initial hearing, no one opposed the petition, so the RTC entered a general default against everyone except the Republic of the Philippines. After compliance with jurisdictional requirements, the RTC allowed Henry, Certeza, and Rosalina to submit evidence before a commissioner. The commissioner found them to be the grandchildren in the direct line of Antonio and required additional evidence to establish the fraternal relationship between Antonio and Hermogenes.

Based on the commissioner's report, the RTC rendered a Partial Judgment on May 31, 1990, declaring Henry, Certeza, and Rosalina as heirs of Antonio, Macario, and Delfin, and appointing Henry as the administrator of the estates. Henry filed the bond and took his oath as the administrator.

After the partial judgment, six opposition groups entered their appearances, with only one group opposing the estate of Antonio and the rest opposing the estate of Hermogenes. Among the oppositors was Jaime Robles, who prayed to be appointed as the regular administrator of both estates and requested permission to sell a portion of land included in Hermogenes' estate. The RTC issued an order on December 15, 1994, declaring Robles as an heir and qualified to be the administrator.

On April 27, 1999, the RTC dismissed the oppositions of Robles and others for their failure to substantiate their claims of heirship to Hermogenes. However, on August 13, 1999, the RTC issued an amended decision reversing its earlier finding and declaring Henry, Certeza, and Rosalina as the heirs of Hermogenes.

Robles appealed the August 13, 1999 amended decision but was denied due to failure to file a record on appeal. Robles then filed a petition for review on certiorari with the Supreme Court, which referred the case to the Court of Appeals (CA). On April 16, 2002, the CA annulled the August 13, 1999 amended decision of the RTC.

Rodriguez and his group filed a motion for reconsideration with the CA, but it was denied. They did not appeal the CA decision, while Robles filed an appeal with the Supreme Court, which was denied on August 1, 2005.

On May 13, 2008, the instant petition was filed by petitioner Rene B. Pascual, seeking the allowance of his petition for certiorari. The petitioner alleged that the CA decision was issued in grave abuse of discretion, and the order of the RTC based on the CA decision was also issued in grave abuse of discretion.

ISSUES:

  1. Whether petitioner has the personality to file the instant petition.

  2. Whether the instant petition should be dismissed.

  3. Whether intervention can be allowed when the trial court has already rendered its Decision and the Court of Appeals has rendered its own Decision on appeal.

RULING:

  1. Petitioner does not have the personality to file the instant petition. The requirement of personality is mandated by Section 1, Rule 65 of the Rules of Court, which states that a person aggrieved by any act of a tribunal, board, or officer exercising judicial or quasi-judicial functions rendered without or in excess of jurisdiction or with grave abuse of discretion amounting to lack or excess of jurisdiction may file a petition for certiorari. The term "person aggrieved" does not mean that any person who feels injured by the lower court's order or decision can question it via certiorari. Only a party to the original proceedings that gave rise to the original action for certiorari can be considered aggrieved. In this case, the petitioner was never a party to the proceedings in the Regional Trial Court (RTC) and the Court of Appeals (CA). Therefore, he does not have standing to file the petition.

  2. The instant petition should be dismissed. Petitioner's admission that he is a third party in the instant case further strengthens the Court's ruling that he does not have standing to question the assailed order and decision. Moreover, the fact that petitioner acquired an interest in a portion of the properties subject to the estate proceedings only in January 2005, long after the proceedings in the RTC and CA, does not justify allowing him to file the petition. Allowing intervention at this stage would resurrect settled issues and disrupt the finality of the decision on appeal. Finally, Section 2, Rule 19 of the Rules of Court provides that a motion to intervene may be filed at any time before rendition of judgment by the trial court, which means that petitioner's motion to intervene is already time-barred.

  3. The Court ruled that intervention cannot be allowed when the trial court has already rendered its Decision, and much less, when the Court of Appeals has rendered its own Decision on appeal. This is in line with the amended Section 2, Rule 19 of the Rules of Court, which states that intervention may be filed "at any time before rendition of the judgment by the trial court." The rationale behind this amendment is that before judgment is rendered, the court may still allow the introduction of additional evidence, and the matter subject of the intervention may still be readily resolved and integrated in the judgment disposing of all claims in the case. In this case, the disputed Decision had already become final and executory when the petitioner filed the instant petition on the sole basis that he acquired an interest in a portion of the disputed estate. Thus, intervention was no longer allowed.

PRINCIPLES:

  • An aggrieved party under Section 1, Rule 65 of the Rules of Court refers to one who was a party to the original proceedings that gave rise to the original action for certiorari.

  • Only a party in the proceedings before the lower court has standing to file a motion for reconsideration and question the order or decision before the appellate court via certiorari.

  • A person not a party to the proceedings in the trial court or appellate court cannot maintain an action for certiorari to have the judgment reviewed.

  • Intervention may be filed at any time before rendition of judgment by the trial court, as provided in Section 2, Rule 19 of the Rules of Court.

  • A decision that has acquired finality becomes immutable and unalterable, and the orderly administration of justice requires that judgments reach a point of finality set by the law. (Mocorro, Jr. v. Ramirez)

  • The exceptions to the rule on the immutability of final judgments are the correction of clerical errors, nunc pro tunc entries with no prejudice to any party, and void judgments.