Trazo v. Manila Pencil Co.
REITERATIONFacts
The Antecedents: On October 19, 1959, the Court of First Instance of Manila rendered judgment in Civil Case No. 39864, ordering the Director of Lands to execute a deed of sale in favor of Manila Pencil Company, Inc. for Lots Nos. 11 and 79 of the San Lazaro Friar Lands. The Director of Lands appealed this decision to the Supreme Court (G.R. No. L-16275), but the appeal was dismissed. Procedural History: On November 6, 1959, Concordio A. Trazo filed an "Omnibus Motion for Leave of Court to Intervene To Set Aside the Decision of October 19, 1959 and for New Trial." Trazo alleged he was the actual occupant of 200 square meters of Lot No. 79 since 1949 under a sublease with Manila Pencil Company, claiming the decision was obtained by fraud due to misrepresentation of occupancy and failure to notify him. He admitted receiving a notification letter but claimed to have received it in early October 1959, despite its August 17, 1959 date. On November 7, 1959, the judge denied Trazo's motion, stating intervention is not permitted after judgment, and also approved the record on appeal of the Director of Lands. The Petition: Trazo subsequently filed a petition for mandamus and certiorari seeking to annul the judgment, suspend proceedings, and reopen the case for his intervention. He reiterated his claims of fraud and misrepresentation, and cited the case of Falcasantos vs. Falcasantos to support his assertion of being an indispensable party.
Issue(s)
Whether the denial of the motion for intervention was proper. Whether petitioner Concordio A. Trazo is an indispensable party whose intervention should have been allowed. Whether the decision in Civil Case No. 39864 was obtained by fraud.
Ruling
The petition is denied. The decision in Civil Case No. 39864 is final and executory. Petitioner's rights, if any, can be protected in a separate proceeding.
Ratio Decidendi
On the propriety of denying the motion for intervention: The Supreme Court held that intervention may be permitted "at any period of a trial," which has been construed to mean the period for the presentation of evidence by both parties. Since Trazo's motion for intervention was filed after the trial had concluded and a decision had been rendered, it was filed out of time. The Court cited Felismeno v. Gloria and Bool v. Mendoza for the interpretation of "at any period of a trial," and Goan v. Azores and El Hogar Filipino v. National Bank for the principle that intervention is not permitted after trial conclusion. Therefore, the denial of the motion was in accordance with the Rules of Court. On whether petitioner is an indispensable party: The Court found that Trazo was not an indispensable party with respect to the right of action between Manila Pencil Company and the Director of Lands. Trazo had no part in the agreement between these two original parties. Consequently, his intervention would unduly prejudice the adjudication of their rights. The Court emphasized that if Trazo has any cause of action, it can be fully protected in a separate proceeding, and he should file an independent action to assert his claims. On whether the decision was obtained by fraud: While Trazo alleged fraud due to misrepresentation and lack of notice, the Court did not directly rule on this issue as it found the intervention motion to be out of time and Trazo not an indispensable party. The Court noted that the decision in Civil Case No. 39864 was already final and executory, having been dismissed by the Supreme Court. The Court's focus was on the procedural aspect of intervention, concluding that any grievance Trazo might have should be pursued through a separate legal action, thereby implicitly suggesting that the alleged fraud did not warrant setting aside a final judgment through an intervention motion.
Main Doctrine
Intervention may not be permitted after trial has been concluded and the decision has become final and executory, as the motion for intervention would be out of time. If the intervenor has any right of action, such rights can be fully protected in a separate proceeding.