FACTS:
Conrado Nobleza, Sr. owned a parcel of land in Iloilo City. He had children from two marriages and three illegitimate children. Santiago claimed to have purchased shares of the subject land from certain heirs after Conrado, Sr.'s death. However, the sale was not signed by all the heirs, and Santiago was unable to transfer the title. Santiago filed a complaint for judicial partition and receivership. The other heirs argued that Santiago had no legal right to file the action because he did not pay the full purchase price and that the subject land was a conjugal asset of Conrado, Sr. and his second wife, making only legitimate heirs eligible to inherit it.
The RTC ruled in favor of Santiago, ordering the partition of the land and cancellation of the title. Santiago was also directed to pay the remaining balance according to the supplemental contract. The respondents appealed to the CA, which dismissed Santiago's complaint for failing to include all the necessary parties. The heirs of Santiago filed a petition for review with the Supreme Court to challenge the CA's ruling.
ISSUES:
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Whether or not the siblings of Felcon and the children of Cebeleo, Sr. and Maude are indispensable parties to the complaint for judicial partition filed by Santiago.
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Whether or not Santiago's complaint should be dismissed for his failure to implead the omitted heirs.
RULING:
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Yes, the siblings of Felcon and the children of Cebeleo, Sr. and Maude are indispensable parties to the complaint for judicial partition filed by Santiago.
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Yes, Santiago's complaint should be dismissed for his failure to implead the omitted heirs.
PRINCIPLES:
- Only those who are indispensable parties must be impleaded in a complaint for judicial partition. Failure to implead an indispensable party may result in the dismissal of the complaint.