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METROPOLITAN BANK v. PRESIDING JUDGE

FACTS:

Petitioner Metropolitan Bank and Trust Co. (Metropolitan) filed a complaint for replevin against Uniwide Sales, Inc. and BPI Investment Corporation to recover possession of air conditioning units or, in the event they cannot be recovered, for the defendants to pay the unpaid obligations on the units. Metropolitan alleged that the air-conditioning units were installed on a loan it extended to Good Earth Emporium & Supermarket, Inc. using a deed of chattel mortgage. Raycor Air Control Systems, Inc. filed a motion to intervene in the case, claiming a direct interest in the subject matter. The lower court admitted the intervention complaint and dismissed the main case with prejudice. However, the court later granted the intervenor's motion for reconsideration and admitted the amended complaint in intervention. Petitioner filed a petition for certiorari and mandamus with the Court of Appeals, which dismissed the petition. Petitioner now brings the case to the Supreme Court.

ISSUES:

  1. Whether the dismissal of the case by the original parties without the consent of the intervenor affects the claim of the intervenor.

  2. Whether the intervenor has the same rights as the original parties and is entitled to have their issues tried and determined.

  3. Whether the order admitting the amended complaint in intervention was proper.

  4. Whether the intervention was proper.

RULING:

  1. The dismissal of the case by the original parties without the consent of the intervenor does not affect the claim of the intervenor. Any settlement made by the original parties is ineffective unless the intervenor is a party to it. The intervenor has the right to claim the benefit of the original suit and to prosecute it to judgment. The right of the intervenor cannot be defeated by the dismissal of the suit by the plaintiff after the filing of the petition and notice thereof to the other parties.

  2. The intervenor has the same power as the original parties and is entitled to have the issues raised between them tried and determined. The intervenor is a party to the action and is entitled to relief as though they were themselves a party in the action. The parties to the original suit do not have the power to waive or annul the substantial rights of the intervenor.

  3. The Court upheld the propriety of the order admitting the amended complaint in intervention. The granting of leave to file an amended pleading is within the sound discretion of the trial court, which is subject to limitations such as not substantially changing the cause of action or altering the theory of the case. In this case, the amended complaint in intervention merely supplemented an incomplete allegation of the cause of action stated in the original complaint, so as to submit the real matter in dispute. The amended complaint in intervention did not substantially change the intervenor's cause of action or alter the theory of the case.

  4. The Court stated that the petitioner's failure to timely object to the motion for leave to intervene bars the petitioner from belatedly questioning the validity of the intervention on appeal. Moreover, the trial court granted the motion for intervention, which was not seasonably questioned by the petitioner, indicating the petitioner's approval of the court's action.

PRINCIPLES:

  • Intervention is a proceeding in which a third person is permitted by the court to make themselves a party to a suit or action for the protection of some right or interest alleged to be affected by such proceedings.

  • Any person who has or claims an interest in the matter in litigation may intervene in the action.

  • The intervenor, once allowed to become a party, has the same power as the original parties subject to the court's authority to control the proceedings.

  • The intervenor is entitled to have the issues raised between them and the original parties tried and determined.

  • The settlement or dismissal of the case by the original parties does not affect the claim of the intervenor.

  • The intervenor has the right to claim the benefit of the original suit and to prosecute it to judgment.

  • The dismissal of the main action does not require the dismissal of the action of the intervenor.

  • The intervenor is entitled to be heard like any other party and their claim for affirmative relief shall be preserved and heard regardless of the disposition of the principal action.

  • Requiring the intervenor to refile another case will result in unnecessary delay and expenses and defeat the purpose of intervention which is to expedite litigation and settle the whole controversy among the persons involved.

  • The granting of leave to file an amended pleading is within the sound discretion of the trial court, and once exercised, it will not be disturbed on appeal, except in cases of abuse of discretion.

  • An amendment to a complaint will not be considered as stating a new cause of action if the facts alleged in the amended complaint show substantially the same wrong with respect to the same transaction.

  • Courts should be liberal in allowing amendments to pleadings to avoid multiplicity of suits and to properly determine the real controversies between the parties without unnecessary delay.

  • Failure to timely object to a motion for intervention bars a party from questioning the validity of the intervention on appeal.