GR 133843; (December, 2001) (Digest)
G.R. No. 133547 & G.R. No. 133843 , December 7, 2001
HEIRS OF ANTONIO PAEL, ET AL. and MARIA DESTURA, petitioners, vs. COURT OF APPEALS, JORGE H. CHIN and RENATO B. MALLARI, respondents.
FACTS
This case involves consolidated motions for reconsideration of a prior Supreme Court Decision. The core dispute originated from conflicting land titles. Petitioners, the Heirs of Pael and Maria Destura, challenged the Court of Appeals’ decision which reinstated the titles of respondents Chin and Mallari (TCT Nos. 52928 and 52929). The Supreme Court had affirmed the appellate court’s finding that the title of PFINA Properties, Inc., from whom the Paels claimed derivative rights, was irregularly and illegally issued. The transfer to PFINA was deemed void due to badges of fraud and the fact the Paels had already disposed of their rights earlier, leaving nothing to transfer.
During the pendency of these motions, the University of the Philippines (U.P.) filed a motion for intervention. U.P. claims that the properties covered by the respondents’ titles form part of the U.P. Campus, which is registered under its name in TCT No. 9462. It argues that any ruling on these titles would create a cloud on its ownership. Respondents Chin and Mallari counter that their titled properties are outside and do not overlap with U.P.’s legitimate holdings.
ISSUE
The primary issue for resolution is whether the motions for reconsideration filed by the original petitioners have merit, and secondarily, whether the University of the Philippines should be allowed to intervene at this late stage.
RULING
The Supreme Court denied the petitioners’ motions for reconsideration with finality. The arguments presented were a mere rehash of previously rejected claims. The Court reiterated its agreement with the Court of Appeals’ factual findings, which are conclusive when supported by evidence. The legal conclusion stood that PFINA’s title was void, making the reinstatement of respondents’ titles proper and not a collateral attack.
However, the Court granted U.P.’s motion for intervention. While intervention at this late stage is generally disallowed, the Court exercised its discretion to prevent further multiplicity of suits and to resolve an inescapable issue. Citing Director of Lands v. Court of Appeals and Mago v. Court of Appeals, the Court emphasized that procedural rules should facilitate justice. A substantial conflict exists regarding the boundaries and potential overlapping of the lands claimed by U.P. and the respondents. To avoid new litigation and resolve this conflict speedily, the case was remanded to the Court of Appeals specifically for the reception of evidence on the boundary dispute between intervenor U.P. and respondents Chin and Mallari.
