Pfleider v. Britanico
REITERATIONFacts
The Antecedents: Plaintiff-lessor William G. Pfleider filed an action for rescission of a lease contract against defendant-lessee Serviliana Cordova de Britanico, covering parcels of land and improvements. The complaint also prayed for ejectment, restoration of possession, accrued rentals, attorney's fees, and costs. Procedural History: C. N. Hodges filed a motion for leave to intervene in the rescission case. Hodges claimed that if the court ordered the delivery of possession of the properties, it would nullify a previous decision in another case (Hodges vs. Pfleider) where possession of the same lands was ordered delivered to Hodges. The lower court denied Hodges' motion to intervene. The Petition: Hodges appealed the denial of his motion for leave to intervene.
Issue(s)
Whether the lower court erred in disallowing the intervention of C. N. Hodges.
Ruling
The order appealed from is affirmed. Costs against appellant C. N. Hodges.
Ratio Decidendi
On Whether the lower court erred in disallowing the intervention of C. N. Hodges: The Supreme Court held that the rule on intervention allows the trial court to exercise discretion. No showing was made that such discretion was abused. The Court affirmed the trial court's denial because the intervenor-appellant's rights were fully protected in Civil Case No. 6146, an interpleader case pending in the same court, where the issues were practically the same. This is a valid ground for denying intervention under Section 2(b) of Rule 12 of the Revised Rules of Court, which states that the court shall consider whether the intervention will unduly delay or prejudice the adjudication of the rights of the original parties and whether the intervenor's rights may be fully protected in a separate proceeding. Furthermore, any judgment rendered in the rescission case, an action in personam, would not prejudice appellant Hodges, who was not an original party to that action. The Court found no reversible error in the trial court's order.
Main Doctrine
The denial of a motion for leave to intervene is a matter of discretion, and such discretion is not abused when the intervenor's rights can be fully protected in another pending proceeding, such as an interpleader action, and when the intervention would unduly delay or prejudice the adjudication of the rights of the original parties.