FACTS:

Marciano A. Roxas passed away, leaving behind his widow and children. In 1955, the heirs of Marciano filed a case against the heirs of Gregorio Galindo to compel them to execute a deed of absolute sale over Lot 1048. The land had been possessed by Gregorio, who purchased it from the government in 1911. After Gregorio's death, his heirs, including his grandson Federico de Guzman, sold their rights to Marciano, except for Urbano Galindo who was a minor. The sale agreement obligated the signatories to transfer the land to Marciano in the future. Urbano later ratified the sale. Marciano had been paying the installments due for the land and it was declared for tax purposes in his name. In 1948, a title was issued in the name of Gregorio's legal heirs due to Urbano's minority. The court ruled in favor of the plaintiffs, ordering the defendants to execute a deed of absolute sale transferring the land to Marciano's heirs. The decision became final and executory but was never enforced. Urbano died, and his widow and children executed an extrajudicial settlement of his estate and Gregorio's estate.

The case revolves around Lot 1048, with the plaintiffs, heirs of Marciano, seeking the annulment of documents, cancellation of the title, and damages. The plaintiffs claim ownership based on a court decision. The defendant presents an extrajudicial settlement executed by the heirs of Urbano Galindo and Gregorio Galindo, asserting ownership and waiving their rights in favor of the defendant. The trial court denied the defendant's motion to dismiss, ruling that the plaintiffs had legal capacity to sue and their cause of action was not barred by the statute of limitations. The defendant's motion for reconsideration was also denied, as was her petition for certiorari before the Court of Appeals. The defendant, along with other Galindo family members, now seeks relief from the Supreme Court through a petition for review on certiorari.

ISSUES:

1. Whether the other petitioners, who were not parties in the lower courts, should be impleaded as parties-petitioners in this case.

2. Whether the trial court committed a grave abuse of its discretion in denying the motion to dismiss on the ground of the respondents' failure to sufficiently allege and prove the representative capacity of Reginald Roxas.

3. Whether the deceased plaintiffs have the capacity to sue or be sued as parties-plaintiffs.

4. Whether the action filed by the plaintiffs is for quieting of title or for the enforcement of a court decision.

5. Whether the action filed by the respondents is an action for enforcement of the decision of the CFI in Civil Case No. 1067.

6. Whether the respondents' prayer for the nullification of the extrajudicial settlement, affidavit of loss, and the title is incidental to their plea to quiet title.

7. Whether the assailed decision of the Court of Appeals should be reversed and set aside.

8. Whether the Regional Trial Court of Bulacan should dismiss the complaint filed.

RULING:

1. The other petitioners, although not parties in the lower courts, are deemed indispensable parties and should be impleaded as parties-petitioners in this case.

2. The trial court committed a grave abuse of its discretion in denying the motion to dismiss based on the respondents' failure to sufficiently allege and prove the representative capacity of Reginald Roxas.

3. The deceased plaintiffs, namely Maximiano Roxas, Benjamin Roxas, Eleazar Roxas, Prescilla Roxas-de Perio, Virginia Roxas-Santos, and Uriel Roxas, do not have the capacity to sue or be sued as parties-plaintiffs. A deceased person does not have the legal entity necessary to bring an action, and an estate is not a legal entity. Therefore, the motion to substitute the deceased plaintiffs should be denied.

4. The action filed by the plaintiffs is for quieting of title under the second paragraph of Rule 63 of the Rules of Court and not for the enforcement of a court decision. The nature of an action and the court's jurisdiction are determined by the material allegations of the complaint, the law existing at the time of filing, and the relief prayed for by the plaintiff. The caption of the complaint is not determinative of the nature of an action.

5. The action filed by the respondents is not an action for enforcement of the decision of the CFI in Civil Case No. 1067. The respondents did not pray for the execution of a deed of absolute sale over the property, reconveyance of the property, or issuance of a new title in their names. The respondents' prayer for the nullification of the extrajudicial settlement, affidavit of loss, and the title is merely incidental to their plea to quiet title. An action to quiet title is imprescriptible.

6. The assailed Decision of the Court of Appeals is reversed and set aside. The Regional Trial Court of Bulacan is ordered to dismiss the complaint.

PRINCIPLES:

• Only parties and their privies and successors-in-interest are bound by the order or decision of the trial court. Non-parties should not be bound or adversely affected to protect their right to due process.

• The absence of indispensable parties renders subsequent actions of the court null and void.

• The burden of proving the sufficiency of representative capacity lies on the party bringing the suit.

• Unauthorized complaints have no legal effect and do not confer jurisdiction over the court.

• The names of the parties should be included in the caption of the original complaint.

• A deceased person does not have the capacity to sue or be sued as a party in a court action.

• An estate is not a legal entity and cannot be a party in a court action.

• The jurisdiction of the court cannot depend on the consent or waiver of the parties.

• The nature of an action and the court's jurisdiction are determined by the material allegations of the complaint, the law existing at the time of filing, and the relief prayed for by the plaintiff.

• An action to quiet title is imprescriptible.

• The nullification of a deed and title may be incidental to a plea to quiet title.

• The court has the power to reverse and set aside a decision if it finds that the lower court committed an error in its ruling.

• The Regional Trial Court has the authority to dismiss a complaint if it finds that the claim has no basis or is invalid.