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REPUBLIC OF THE PHILIPPINES REPRESENTED BY THE PHILIPPINE RECLAMATION AUTHORITY V Ria Rubin

The Supreme Court ruled that while the Philippine Reclamation Authority (PRA) had a legal interest in the subject lots over which it asserted ownership, allowing its intervention in the case would delay and prejudice the adjudication of the original parties' rights. Specifically, the Court found that PRA's asserted rights and interests had already been protected through other legal proceedings, including a decision recognizing PRA's ownership of the lots. Therefore, the requirements for intervention were not fully met and PRA's motion to intervene was properly denied.

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ALEXIR MENDOZA
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242 views2 pages

REPUBLIC OF THE PHILIPPINES REPRESENTED BY THE PHILIPPINE RECLAMATION AUTHORITY V Ria Rubin

The Supreme Court ruled that while the Philippine Reclamation Authority (PRA) had a legal interest in the subject lots over which it asserted ownership, allowing its intervention in the case would delay and prejudice the adjudication of the original parties' rights. Specifically, the Court found that PRA's asserted rights and interests had already been protected through other legal proceedings, including a decision recognizing PRA's ownership of the lots. Therefore, the requirements for intervention were not fully met and PRA's motion to intervene was properly denied.

Uploaded by

ALEXIR MENDOZA
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Remedial Law: Intervention

REPUBLIC OF THE PHILIPPINES REPRESENTED BY THE PHILIPPINE


RECLAMATION AUTHORITY (PRA) v RIA S. RUBIN
G.R. No. 213960, October 07, 2020, FIRST DIVISION (Lazaro-Javier, J.)

FACTS: On February 4, 1977, President Ferdinand E. Marcos issued Presidential


Decree No. 10854 (PD 1085) decreeing that the "land reclaimed in the foreshore and
offshore areas of Manila Bay" is "hereby transferred, conveyed and assigned to the
ownership and administration of the Public Estates Authority (now petitioner
Philippine Reclamation Authority or PRA)." In 1988 Philippine Reclamation Authority
(PRA) submitted to the DENR its Survey Plan for the purpose of securing a Special
Land Patent on a reclaimed land Pending issuance of a Special Land Patent in its
favor. PRA entered into a Memorandum of Agreement with MERALCO where it granted
MERALCO permission to construct and maintain a substation on a 10,000 square
meter portion of the lots. PRA discovered that Espinili Laderas and Edna Laborte both
applied for a Miscellaneous Sales Application and the DENR-NCR approved both. Ria
Rubin bought from Laderas Lot 12 and from Laborte Lot 13 through absolute deeds of
sale.
Ria Rubin filed before the Regional Trial Court an accion reivindicatoria against
MERALCO while PRA filed for cancellation of the miscellaneous sales patents, original
certificates of title, and transfer certificates of title, plus, reversion. PRA through an
Omnibus Motion for Intervention and admit answer-in-intervention asserted that it is
the absolute owner of the lots while Ria Rubin riposted that the PRA had no right to
intervene and that valid titles and the same cannot be collaterally attacked through a
mere intervention.
The Regional Trial Court ruled against the intervention and the Court of
Appeals affirmed said ruling stating that PRA had not been given special patent over
the subject lots thus it had not shown such kind of legal interest that would be
directly affected by whatever judgment may be rendered in the accion reinvindicatoria
case.

ISSUE: Is PRA's omnibus motion to intervene and admit the answer-in-intervention


proper?

RULING: No. Intervention 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.
Remedial Law: Intervention

In sum, to allow intervention, (a) it must be shown that the movant has
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. Both requirements must
concur.
The first element is present here as PRA has legal interest over the lots over
which it asserts its claim of ownership and possession in conflict with or adverse to
that of Ria Rubin as it was PRA who was the lessor to MERALCO. However, the second
element is not present as there is no denying that petitioner's asserted right or interest
in the lots has so far been more than amply protected. In fact, even the Regional Trial
Court itself has recognized, in no uncertain terms, the existence and legal
consequence of that Decision on the pending accion reinvindicatoria case before it. It is
precisely for this reason that the Regional Trial Court promptly ordered the
suspension of the proceedings before it pending the finality of the aforesaid Decision.

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