02/05/2025
If [the parent] was a party to the Rule 45 petition before Us and served copies of the petition and other pleadings, she could have been held liable under Article 219 of the Family Code, which provides that parents may be held subsidiarily liable for damages caused by the acts or omissions of the unemancipated minor. ### However, it is evident that [the parent] was no longer included as a party and thus not served copies of the Petition or other pleadings and notices in the proceedings before Us. ###
It is settled that a judgment binds only those who were parties to the case, for no person shall be adversely affected by the outcome of a civil action or proceeding in which he/she is not a party. The principle that a person cannot be prejudiced by a ruling rendered in an action or proceeding in which he or she has not been made a party conforms to the constitutional guarantee of due process of law.
In fine, the Court shall not hold [the parent] subsidiarily liable for damages to the Heirs, since she is not a party to the proceedings before the Court. To rule otherwise would be to countenance deprivation of property without ample notice, and antithetical to fair play and due process.
Apolinario vs. Heirs of De Los Santos, G.R. No. 219686, 27 November 2024