FRUMENCIO E. PULGAR v. RTC OF MAUBAN

FACTS:

Respondent Quezon Power (Philippines) Limited, Co. (QPL) owned and operated the Mauban Plant, a coal-fired electric generation facility, which was assessed with realty taxes amounting to P29,626,578,291.00. QPL filed a complaint for consignation and damages against the Province of Quezon and other government officials, disputing the assessment. Petitioner, Frumencio E. Pulgar, filed a motion for intervention, claiming an interest in the collection of realty taxes. The Regional Trial Court (RTC) dismissed the main case for lack of jurisdiction and consequently dismissed Pulgar's motion for intervention.

ISSUES:

  1. Whether or not the RTC erred in dismissing Pulgar's motion for intervention as a consequence of the dismissal of the main case.

RULING:

  1. The Supreme Court held that the RTC did not err in dismissing Pulgar's motion for intervention. Jurisdiction over an intervention is subject to the jurisdiction over the main action. Since the main case was dismissed for lack of jurisdiction, Pulgar's right to intervene also ceased. Intervention is ancillary and supplemental to the existing litigation and is meant to aid the right of the original party. In this case, since the right of the original party (QPL) has ceased to exist due to the dismissal of the main case, there was nothing for Pulgar to fight for or protect, and thus, his intervention was properly dismissed.

PRINCIPLES:

  • Intervention is ancillary and supplemental to the existing litigation and is meant to aid the right of the original party.

  • The right of an intervenor ceases to exist when the right of the original party has ceased to exist.