Pinlac VS Ca
Pinlac VS Ca
Pinlac VS Ca
PINLAC VS CA (2003)
DOCTRINE: The rule on intervention, like all other rules of procedure is intended to make the powers of the
Court fully and completely available for justice. It is aimed to facilitate a comprehensive adjudication of rival
claims overriding technicalities on the timeliness of the filing thereof.
FACTS:
Petitioners filed a Petition for Quieting of Title over 3 vast parcel of land.
Trial Court rendered a partial decision in favour of petitioners and against defendants who were
declared in default.
Defaulted title owners filed an appeal with the CA. CA granted because TC did not acquire
jurisdiction over the person of the respondents because of defective service of summons by
publication.
Petitioners appealed to the SC but the SC affirmed the decision of CA
On motion for recon, petitioners alleged that the CA should not have annulled the disposition of the
TC with respect to Lot No. 3 because the petition for annulment of judgment filed by the
respondents concerned only Lot No. 2
Nov. 20, 2001 SC granted the motion and reinstated the disposition made by the TC with respect
to Lot No. 3
On July 22, 2002, the Republic of the Philippines filed a motion for intervention and Petition-in-
Intervention
ISSUE: WON the Republic should be allowed to intervene
HELD: YES. The rule on intervention, like all other rules of procedure is intended to make the powers of the
Court fully and completely available for justice. It is aimed to facilitate a comprehensive adjudication of rival
claims overriding technicalities on the timeliness of the filing thereof. Indeed, in exceptional cases, the
Court has allowed intervention notwithstanding the rendition of judgment by the trial court. In one case,
intervention was allowed even when the petition for review of the assailed judgment was already submitted
for decision in the Supreme Court.
The SC cited Director of Lands v. Court of Appeals, where the motions for intervention were filed
when the case had already reached this Court, it was declared:
It is quite clear and patent that the motions for intervention filed by the movants at this stage of the
proceedings where trial had already been concluded x x x and on appeal x x x the same was affirmed by
the Court of Appeals and the instant petition for certiorari to review said judgment is already submitted for
decision by the Supreme Court, are obviously and manifestly late, beyond the period prescribed under x x x
Section 2, Rule 12 of the Rules of Court [now Rule 19, Section 2 of the 1997 Rules on Civil Procedure].
But Rule 12 of the Rules of Court, like all other Rules therein promulgated, is simply a rule of procedure,
the whole purpose and object of which is to make the powers of the Court fully and completely available for
justice. The purpose of procedure is not to thwart justice. Its proper aim is to facilitate the application of
justice to the rival claims of contending parties. It was created not to hinder and delay but to facilitate and
promote the administration of justice. It does not constitute the thing itself which courts are always striving
to secure to litigants. It is designed as the means best adopted to obtain that thing. In other words, it is a
means to an end.
The intervention of the Republic is necessary to protect public interest as well as government
properties located and projects undertaken on Lot No. 3. The Constitutional mandate that no person shall
be deprived of life, liberty, or property without due process of law can certainly be invoked by the Republic
which is an indispensable party to the case at bar. As correctly pointed out by the Solicitor General, while
the provision is intended as a protection of individuals against arbitrary action of the State, it may also be
invoked by the Republic to protect its properties
NOTE: Lot No. 3 is where the National Government Center Housing Project (NGCHP) and the NGC-
EASTSIDE DEVELOPMENT PROJECT, the following government buildings, offices and complexes are
situated:
1) House of Representatives;
2) Civil Service Commission (CSC);
3) Department of Social Works and Development (DSWD);
4) Sandiganbayan;
5) Commission on Audit (COA);
6) Department of Public Works and Highways (DPWH) Depot;
7) Polytechnic University of the Philippines (PUP) Commonwealth Campus;
8) TESDA Skills Training Center;
9) Several Public Elementary and High Schools, Health Centers and Barangay Halls.