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REPUBLIC v. RIA S. RUBIN

FACTS:

In 1977, President Ferdinand E. Marcos issued Presidential Decree No. 1085, transferring the ownership and administration of reclaimed land in Manila Bay to the Philippine Reclamation Authority (PRA). The PRA submitted a survey plan in 1988 for a reclaimed land in Las Piñas City and entered into a Memorandum of Agreement with Manila Electric Company (MERALCO) for the construction of a substation on a portion of the land. However, issues arose when the original survey plan was lost and a new one was approved without the PRA's clearance. Portions of the land were also awarded to two individuals through Miscellaneous Sales Patents. The Land Registration Authority cancelled the original patents and issued new ones, reducing the areas and renumbering the lots. The new patents were registered with the Register of Deeds of Las Piñas City.

In a separate matter, Espinili Laderas and Edna Laborte obtained patents for two separate lots and were issued Original Certificates of Title (OCT) in their names. Espinili Laderas sold Lot 12 to respondent Ria S. Rubin, who requested the subdivision of the lot into two. TCT No. T-107910 was cancelled and TCT No. T-110051 (Lot 12-A) and TCT No. T-110051 (Lot 12-B) were issued in respondent's name. Edna Laborte also sold Lot 13 to respondent, and TCT No. T-107914 was issued in respondent's name.

Respondent filed a complaint against MERALCO, seeking the surrender of the lots. MERALCO, in turn, filed a complaint for cancellation of the titles and reversion. Both cases were filed before the Regional Trial Court (RTC) in Las Piñas City, with respondent's case assigned to Branch 255 and MERALCO's case assigned to Branch 198.

Petitioner, represented by the Office of the Solicitor General (OSG), filed an omnibus motion to intervene and admit an attached answer-in-intervention. Respondent opposed the intervention, arguing that petitioner had no direct evidence of ownership and should file a separate proceeding for its claim. MERALCO also opposed the intervention, claiming that its right to possess the lots was derived from its lease contract with petitioner.

Branch 255 denied petitioner's motion to intervene, asserting that it had no authority to pre-empt the jurisdiction of Branch 198. Petitioner's motion for reconsideration was likewise denied. Consequently, petitioner filed a special civil action for certiorari before the Court of Appeals, alleging grave abuse of discretion on the part of the trial court.

ISSUES:

  1. Whether the petitioner has legal interest to intervene in the case for recovery of ownership and possession.

  2. Whether the petitioner would be guilty of forum shopping if allowed to intervene.

  3. s petitioner's omnibus motion to intervene and admit answer-in-intervention in Civil Case No. LP-11-0026 proper?

  4. Whether or not the decision rendered by Branch 198, declaring the titles as null and void, is determinative of the issue raised in the instant case.

  5. Whether or not the trial court and the Court of Appeals correctly denied petitioner's omnibus motion to intervene and admit answer-in-intervention.

RULING:

  1. The Court of Appeals ruled that the petitioner does not have the legal interest to intervene in the case for recovery of ownership and possession. The petitioner has not been granted a special land patent over the subject lots and its interest is at best inchoate.

  2. The Court of Appeals also ruled that allowing the petitioner to intervene would amount to forum shopping. The petitioner had filed a reversion case against the respondent involving the same lots, and if allowed to intervene in the accion reinvindicatoria case, it would be committing forum shopping.

  3. ntervention is a remedy by which a third party, not originally impleaded in the proceedings, becomes a litigant therein to enable him or her to protect or preserve a right or interest which may be affected by such proceedings. It is, however, settled that intervention is not a matter of right, but is instead addressed to the sound discretion of the courts and can be secured only in accordance with the terms of the applicable statute or rule.

  4. The decision rendered by Branch 198, declaring the titles as null and void, is determinative of the issue raised in the instant case. If the decision is affirmed by a higher court, it will affect not only one individual but all existing consumers of the defendant. On the other hand, if the decision is reversed, the instant case will be decided in accordance with the evidence presented. The finality of the decision in Branch 198 is crucial to the plaintiff's claim of her right to possess the subject properties.

  5. The trial court and the Court of Appeals correctly denied petitioner's omnibus motion to intervene and admit answer-in-intervention. The deference of Branch 255 to Branch 198 and its recognition that the parties' dispute will be fully settled in the reversion case is a practical and sensible approach. The existence of conflicting decisions and possible complications that may arise in the execution of such decisions justify the denial of petitioner's motion.

PRINCIPLES:

  • A party seeking to intervene in a case must have legal interest in the subject matter of the case.

  • Forum shopping is the act of a party of filing multiple cases involving the same parties and issues, in order to have a favorable ruling from separate courts.

  • Intervention is not a matter of right, but is addressed to the sound discretion of the courts and can be secured only in accordance with the terms of the applicable statute or rule.

  • What qualifies a person to intervene is his or her possession of a legal interest in the matter in litigation or in the success of either of the parties, or an interest against both; or when he or she is so situated as to be adversely affected by a distribution or other disposition of property in the custody of the court or an officer thereof.

  • Permission to intervene is subject to the sound discretion of the court, which is limited by considering whether or not the intervention will unduly delay or prejudice the adjudication of the rights of the original parties and whether or not the intervenor's rights may be fully protected in a separate proceeding.

  • To allow intervention, both requirements must concur: (a) the movant has a legal interest in the matter in litigation, or is otherwise qualified; and (b) consideration must be given as to whether the adjudication of the rights of the original parties may be delayed or prejudiced, or whether the intervenor's rights may be protected in a separate proceeding or not.

  • The finality of a decision is determinative of the issue raised in a case, particularly when it affects multiple individuals.

  • Deference to another court's decision and waiting for the final resolution of a related case can be a practical and sensible approach to avoid conflicting decisions and complications in execution.