Lacuna v. Board of Liquidators
REITERATIONFacts
The Antecedents: The case involves a dispute where the assignor, Cirilo Damian, sought to intervene as an indispensable party. Procedural History: The Supreme Court had previously issued a resolution ordering the remand of the records to the court of origin to allow the intervention of the assignor. The Petition: Petitioner Salvador D. Lacuna filed a Motion for Reconsideration of the Supreme Court's resolution. Additionally, Cirilo Damian filed a Verified Urgent Manifestation waiving his right to intervene as an indispensable party.
Issue(s)
Whether the Motion for Reconsideration filed by the petitioner was filed out of time. Whether the Court should reiterate its resolution ordering the remand of the records for the intervention of an indispensable party.
Ruling
The Supreme Court denied the Motion for Reconsideration filed by petitioner Salvador D. Lacuna for having been filed out of time. The Court reiterated its Resolution of November 28, 1964, ordering the remand of the records to the court of origin for the purpose of allowing the assignor's intervention as an indispensable party. The proceedings on remand were limited to the presentation of evidence by the intervenor-appellant and the corresponding rebuttal evidence by the other parties.
Ratio Decidendi
On Whether the Motion for Reconsideration was filed out of time: The Court resolved to deny the Motion for Reconsideration filed by petitioner Salvador D. Lacuna. The denial was based on the ground that the motion was filed out of time. This signifies the strict adherence to procedural rules regarding the timeliness of motions for reconsideration, which are crucial for the finality of judgments and the orderly administration of justice. Failure to file within the reglementary period renders the motion a mere scrap of paper, devoid of legal effect. On Whether the Court should reiterate its resolution ordering the remand of the records for the intervention of an indispensable party: The Court reiterated its previous resolution ordering the remand of the records to the court of origin. This action was taken to allow the intervention of Cirilo S. Damian as an indispensable party. The Court emphasized that the proceedings on remand should be strictly limited to the presentation of evidence by the intervenor-appellant and the corresponding rebuttal evidence by the other parties. This underscores the fundamental principle that all indispensable parties must be included in a litigation to ensure a complete and final determination of the controversy.
Main Doctrine
The Supreme Court, in its Resolution, denied the Motion for Reconsideration filed by petitioner Salvador D. Lacuna for being filed out of time. It reiterated its prior resolution to remand the case to the court of origin to allow the intervention of Cirilo S. Damian as an indispensable party. The proceedings on remand were strictly limited to the presentation of evidence by the intervenor-appellant and the rebuttal evidence by the other parties.