12/07/2023
CATEDRILLA v. LAURON, G.R. No. 179011 - April 15, 2013
Doctrine: Compulsory joinder of indispensable parties refers to the requirement that parties who are necessary for a complete and final resolution of a legal action must be included as plaintiffs or defendants. In the case of co-ownership, not all co-owners need to be impleaded individually because they are collectively considered indispensable parties. Instead, it is acceptable for one co-owner to represent the interests of the other co-owners in the lawsuit.
Facts:
In this case, petitioner Rey Castigador Catedrilla filed a complaint for ejectment against spouses Mario and Margie Lauron in the Municipal Trial Court (MTC) of Lambunao, Iloilo. The petitioner alleged that he is a co-owner of a parcel of land known as Lot 183, which was initially owned by Lorenza Lizada and later succeeded by her sole heir, Jesusa Lizada Losañes, who was married to Hilarion Castigador. Jesusa and Hilarion had a daughter named Lilia, who was married to Maximo Catedrilla. After Lilia's death, her heirs, including Maximo and petitioner, agreed to subdivide Lot 183, with Lot No. 5 being allocated to Lilia's heirs.
The petitioner claimed that the respondents, Mario and Margie Lauron, constructed a residential building on a portion of Lot No. 5 without permission. The petitioner and other heirs repeatedly demanded that the respondents vacate the premises, but they refused to do so.
In their answer, the respondents argued that they were not the owners of the residential building but Mildred Kascher, sister of respondent Margie. They claimed that Mildred had already paid a downpayment for the subject lot to Teresito Castigador. The respondents also contended that the heirs of Lilia had offered Lot 183 for sale to them and Mildred but without any intention of actually delivering or registering the lot. They further asserted that an amicable settlement was reached between Maximo and respondent Margie in 1998, which should be considered a final judgment and bar the present suit.
In addition to their defense, the respondents counterclaimed for damages.
This case revolves around the issue of ejectment, ownership of Lot 183, and the validity of the residential building constructed by the respondents on Lot No. 5. The court will have to determine the rightful owner of the land and whether the respondents should be ejected from the premises.
The Municipal Trial Court (MTC) issued its decision on November 14, 2003. The court ruled in favor of the plaintiff, ordering the defendants to vacate the lot in question and restore possession to the plaintiff. The defendants were also ordered to pay the plaintiff attorney's fees in the amount of ₱20,000.00, plus ₱1,000.00 for each court appearance, and reasonable compensation for the use of the lot in the amount of ₱1,000.00 per year from the date of demand. The defendants were also directed to pay the costs of litigation. However, no award was made for moral and exemplary damages. The defendants' counterclaim was dismissed due to lack of sufficient evidence.
The MTC determined that the petitioner, as one of the heirs of Lilia Castigador Catedrilla, had the standing to bring the ejectment suit under Article 487 of the Civil Code and Section 1, Rule 70 of the Rules of Court. The court also recognized that the respondents were proper parties to be sued as they were occupying the subject lot without ownership rights. The MTC noted that the house on the lot had been standing before 1992 with the acquiescence of the petitioner and his predecessor-in-interest.
The defendants argued that Mildred, as the owner of the residential building on the lot, was an indispensable party and that there was a perfected contract to sell between Mildred and Maximo based on an amicable settlement before the Punong Barangay. However, the MTC found that respondent Margie represented her parents in the dispute before the Punong Barangay and that Mildred's letter to Maximo acknowledged the latter's title to the lot. The MTC concluded that the defendants could not evade the consequences of their continued occupation of the property. The issue of ownership was considered only to determine who had the better right of possession, and the possession of the lot should be relinquished by the defendants to the petitioner, a co-owner, without affecting any other remedies that Mildred may pursue for her purported rights.
The respondents filed an appeal with the Regional Trial Court (RTC) of Iloilo City, which was assigned to Branch 26. On March 22, 2005, the RTC issued its order affirming the decision of the court dated November 14, 2003, with the exception of the payment of ₱20,000.00 as attorney's fees.
The RTC agreed with the MTC's finding that the petitioner, being one of the co-owners of the subject lot, was the proper party to bring the case against any intruders. It determined that the amicable settlement signed before the Lupon, which was executed by representatives of the registered owner of the premises, was not binding or enforceable between the parties. The RTC also ruled that Mildred, despite having her name on the tax declaration as the owner of the house constructed on the lot, could not be considered an indispensable party in the suit for recovery of possession against the respondents. The court emphasized that tax declarations are not evidence of ownership but are issued for tax payment purposes. As Mildred was not in actual possession of the lot, the court concluded that she should have intervened and proved her status as an indispensable party. The RTC removed the attorney's fees from the judgment because the MTC decision had ordered their payment without any valid basis.
The respondents filed a motion for reconsideration, which was subsequently denied in an order dated June 8, 2005.
Displeased with the decision, the respondents filed a petition for review with the Court of Appeals (CA). The petitioner submitted a comment in response to the petition. On February 28, 2007, the CA issued its decision, reversing and setting aside the judgment of the Regional Trial Court (RTC) that affirmed the Municipal Trial Court (MTC) decision.
The CA found that only the petitioner had filed the ejectment case against the respondents, and ruled that all the other heirs should have been included as plaintiffs according to Section 1 of Rule 7 and Section 7 of Rule 3 of the Rules of Court. The court emphasized that the presence of all indispensable parties is necessary for the exercise of judicial power. As the other heirs were not included as plaintiffs, the CA concluded that the trial court could not validly render judgment and grant relief in favor of the respondents.
Additionally, the CA noted that although the petitioner argued that the proper parties to be sued were the respondents, who were the actual possessors of the lot, he was aware that his co-owners had offered the property for sale to Mildred. Therefore, the petitioner knew all along that Mildred was the true owner of the house on the lot, not the respondents. The CA mentioned that Mildred had even made a partial payment of ₱10,000.00 for the lot and had required the relatives of the respondents to secure the necessary ownership documents. The court pointed out that Maximo and Mildred had previously settled the matter regarding the sale of the lot before the Barangay, as evidenced by an amicable settlement signed by Maximo and respondent Margie. Considering these circumstances, the CA concluded that the question at hand pertained to possessory rights and that the non-inclusion of indispensable parties rendered the complaint fatally defective. The court determined that ejectment, being a summary remedy, was not the appropriate action to file against the alleged deforciant of the property.
Issues:
I. The Court of Appeals (CA) erred in holding that the decision of the trial court was a nullity.
II. The CA erred in holding that the petitioner knew all along that Mildred Kascher, not the respondents, was the real owner of the residential building.
Held:
I. The Supreme Court disagreed with the CA's conclusion and upheld the validity of the trial court's decision. The CA had argued that the other co-heirs should have been impleaded as co-plaintiffs in the ejectment case. However, the Supreme Court cited Article 487 of the Civil Code, which allows any one of the co-owners to bring an action for ejectment without the need to join all other co-owners as co-plaintiffs. The court clarified that in cases involving co-owned properties, only one co-owner is an indispensable party, and the suit is presumed to be filed for the benefit of all co-owners. Therefore, the trial court's decision was valid, and the other co-owners were not required to be included as plaintiffs in the case.
II. The Supreme Court disagreed with the CA's finding that Mildred was an indispensable party and the house on the lot belonged to her. The CA based its conclusion on affidavits and an amicable settlement between Mildred, Maximo, and respondent Margie. However, the Supreme Court determined that the affidavits only stated that the lot was offered for sale to Mildred but did not admit that she was the owner of the house. The court also noted that there were inconsistencies and disputes regarding the settlement. Furthermore, the court emphasized that in ejectment cases, the issue is solely about possession and not ownership. As a co-owner, the petitioner was entitled to bring the action for ejectment against the respondents, who were occupying the lot without any lease agreement. The court reinstated the trial court's order dismissing the complaint for ejectment.
In summary, the Supreme Court upheld the validity of the trial court's decision and rejected the CA's findings, stating that the other co-owners were not required to be included as plaintiffs in the ejectment case. The court also ruled that the petitioner, as a co-owner, had the right to bring the action against the respondents, who were in possession of the lot without a lease agreement. Therefore, the Supreme Court reinstated the trial court's order.
