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    Heirs of Dinglasan v. Ayala Corp., G.R. No. 204378, August 5, 2019.

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    CHRISTY NGALOY
    The Supreme Court of the Philippines partially granted a petition concerning a land dispute between heirs of Juan Dinglasan and Ayala Corporation. The Court ruled that Severina Luna Orosa, in whose name the original land title was allegedly fraudulently issued, was an indispensable party that was not impleaded. It reversed the lower court decisions and remanded the case back to trial court to add indispensable parties and resolve the case on the merits after hearing from these parties.

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    Heirs of Dinglasan v. Ayala Corp., G.R. No. 204378, August 5, 2019.

    Uploaded by

    CHRISTY NGALOY
    55 views3 pages
    The Supreme Court of the Philippines partially granted a petition concerning a land dispute between heirs of Juan Dinglasan and Ayala Corporation. The Court ruled that Severina Luna Orosa, in whose name the original land title was allegedly fraudulently issued, was an indispensable party that was not impleaded. It reversed the lower court decisions and remanded the case back to trial court to add indispensable parties and resolve the case on the merits after hearing from these parties.

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    The Supreme Court of the Philippines partially granted a petition concerning a land dispute between heirs of Juan Dinglasan and Ayala Corporation. The Court ruled that Severina Luna Orosa, in whose name the original land title was allegedly fraudulently issued, was an indispensable party that was not impleaded. It reversed the lower court decisions and remanded the case back to trial court to add indispensable parties and resolve the case on the merits after hearing from these parties.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    55 views3 pages

    Heirs of Dinglasan v. Ayala Corp., G.R. No. 204378, August 5, 2019.

    Uploaded by

    CHRISTY NGALOY
    The Supreme Court of the Philippines partially granted a petition concerning a land dispute between heirs of Juan Dinglasan and Ayala Corporation. The Court ruled that Severina Luna Orosa, in whose name the original land title was allegedly fraudulently issued, was an indispensable party that was not impleaded. It reversed the lower court decisions and remanded the case back to trial court to add indispensable parties and resolve the case on the merits after hearing from these parties.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 3

    HEIRS OF JUAN M. DINGLASAN v. AYALA CORPORATION, GR No.

    204378, 2019-
    08-05
    Facts:
    On February 16, 1996, herein petitioners, through their representative Platon Dinglasan,
    filed an Application for Registration of Title with the RTC of Batangas City, which was
    docketed as Land Registration Case No. N-1515, seeking for the judicial confirmation
    and registration of their title over a... parcel... of land located at Barangay Tabangao,
    Batangas City. The subject land, designated as Lot 11808, Cad-264 of Batangas
    Cadastre, contains an area of Ninety-Three Thousand One Hundred and Twenty
    (93,120) square meters which was subdivided into three (3) lots, namely, Lots 11808-A,
    11808-B and 11808-C with an area of 16,062, 37,571, and 39,489 square meter,
    respectively. Subsequently, several persons filed their respective oppositions, including
    herein private respondents Ayala Corporation (Ayala)... and Omniport Economic Center
    (Omniport) as well as Pilipinas Shell Corporation (Shell). Both Ayala and Omniport
    alleged that they are the registered owners of several lots inside Cadastral Lot 11808,
    as evidenced by separate Transfer Certificates of Title (TCT) in their name, issued by
    the Register of Deeds of Batangas City. Shell, on the other hand, had an existing
    contract of lease over the properties under the name of Ayala. Petitioners' application
    for registration was later amended and was, subsequently, raffled to Branch 8 of the
    RTC of Batangas City (
    4] dated March 3,... Partial Decision[4] dated March 3, 1998... by declaring that the lots
    claimed by Omniport are excluded from the properties being sought to be registered by
    herein petitioners.
    In a separate Order[5] dated November 6, 2000
    Branch 8 found that the lots being claimed by Ayala have already been "brought under
    the Torrens System and for which corresponding [Original Certificates of Title] OCTs or
    TCTs have been issued
    Branch 8 dismissed herein petitioners' application for registration.
    The first Complaint, filed on September 9, 1999 and docketed as Civil Case No. 5413,
    was for cancellation of TCTs and damages against Omniport.
    On... the other hand, the second Complaint, filed on September 7, 2001, later amended
    on November 26, 2001, and docketed as Civil Case No. 6046, was for reconveyance,
    quieting of title and cancellation of TCTs against Ayala, Shell and the Register of Deeds
    of Batangas City
    Petitioners' basic contention in both Complaints is that the TCTs in the names of
    Omniport and Ayala are null and void because the subject lots were never brought
    under registration and that OCT 18989, issued in the name of one Severina Luna Orosa
    (Orosa), from which Omniport's and Ayala's TCTs were ultimately derived, is fake or
    spurious.
    In their defense, Ayala and Shell contended that: the Complaint states no cause of
    action; the Complaint is dismissible... on grounds of prescription and laches; the
    Complaint is defective for failure to implead Orosa who is a necessary party; Ayala is an
    innocent purchaser for having relied on the validity of Orosa's certificate of title... during
    the purchase of the disputed lots; Ayala and Shell are the ones who have been in
    continuous, open and adverse possession of the subject properties in the concept of
    owner; and, petitioners have no personality to question the validity of and ask for the
    nullification of the contract of lease between Ayala and Shell because they are not privy
    thereto.
    RTC... rendered its Decision... against the Plaintiffs and in favor of the Defendants
    Ayala and Shell... petitioners filed an appeal with the CA.
    CA... affirmed the RTC Decision
    Motion for Reconsideration,[13] but the CA denied... instant petition is PARTLY
    GRANTED. The August 31, 2011 Decision and October 18, 2012 Resolution of the
    Court of Appeals in CA-G.R. CV No. 94671, as well as the June 8, 2009 Decision of the
    Regional Trial Court of Batangas City, Branch 8, in Civil Case Nos. 6046 and 5413, are
    hereby REVERSED AND
    Issues:
    THE COURT OF APPEALS GRAVELY ERRED IN RULING THAT THE SPOUSES
    OROSA ARE INDISPENSABLE PARTIES TO THE CASE.
    THE HONORABLE COURT OF APPEALS GRAVELY ERRED IN DECLARING
    PETITIONERS HAD SLEPT ON THEIR RIGHTS AND ARE GUILTY OF LACHES.
    instant petition is PARTLY GRANTED
    Ruling:
    Third, respondent Ayala argues that the instant petition is fatally defective for failure of
    the other petitioners to sign and execute the Verification and Certification Against Forum
    Shopping. In Altres, et al. v. Empleo, et al.,[22] this Court summarized the rules on
    verification and certification against forum shopping, to wit:
    An indispensable party is one who stands to be injured or benefited by the outcome of
    the petition.[26] He has an interest in the controversy that a final decree would
    necessarily affect his rights, such that the courts cannot proceed without his presence.
    [27] It is settled that the joinder of all indispensable parties is required under any and all
    conditions, their presence being a sine qua non of the exercise of judicial power.[28]
    Stated differently, the joinder of indispensable parties is mandatory and courts cannot
    proceed without their presence.[29] The presence of indispensable parties is necessary
    to vest the... court with jurisdiction, which is the authority to hear and determine a
    cause, the right to act in a case.[30] Thus, without the presence of indispensable parties
    to a suit or proceeding, the judgment of a court cannot attain real finality.[31] The
    absence of an indispensable party renders all subsequent actions... of the court null and
    void for want of authority to act, not only as to the absent parties, but even as to those
    present.[32]In the present case, the Court agrees with both the RTC and the CA... that
    Severina Luna Orosa is an indispensable party because the main issue in the instant
    case is whether or not the issuance of OCT 18989, which was alleged to be registered
    under Orosa's name, was fraudulently obtained. Moreover, petitioners seek the
    annulment of OCT 18989 and all its derivative titles
    It is clear that Orosa's rights are directly affected by the present controversy and that
    she stands to be injured by the outcome of the Complaints filed by petitioners. In fine,
    the absence of Orosa in the Complaints filed by petitioners renders all subsequent
    actions of both the RTC and the CA null and void for want of authority to act, not only as
    to the absent parties, but even as to those present.
    the settled rule is that the non-joinder of indispensable parties is not a ground for the
    dismissal of an action.[34] The remedy is to implead the non-party claimed to be
    indispensable.[35] Parties may be added by order of the court on motion of the party or
    on its own initiative at any stage of the action and/or at such times as are just.[36]...
    the... the correct course of action in the instant case is to order its remand to the RTC
    for the inclusion of those indispensable parties who were not impleaded and for the
    disposition of the case on the merits after these parties are given opportunity to present
    their own evidence.
    instant petition is PARTLY GRANTED. The
    Regional Trial Court... instant petition is PARTLY GRANTED. The August 31, 2011
    Decision and October 18, 2012 Resolution of the Court of Appeals in CA-G.R. CV No.
    94671, as well as the June 8, 2009 Decision of the Regional Trial Court of Batangas
    City, Branch 8, in Civil Case Nos.

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