Barangay Matictic v. Elbinias
REITERATIONFacts
The Antecedents: On December 7, 1968, Barrio Matictic filed an injunction case (Civil Case No. SM-210) to enjoin defendants from obstructing a barrio road. On January 28, 1969, the case was dismissed upon motion of Barrio Matictic, recognizing that an expropriation proceeding was the better remedy. On the same date, the Municipality of Norzagaray filed an eminent domain case (Civil Case No. SM-234) involving the same property. Defendants filed motions to dismiss, primarily arguing lack of jurisdiction due to the absence of prior approval from the Office of the President, as required by Section 2245 of the Revised Administrative Code. The plaintiff municipality filed an amended complaint alleging it had obtained the requisite authority. Defendants reiterated their challenge, asserting that subsequent authorization could not cure the initial jurisdictional defect. The court ordered the plaintiff to submit approved plans, which it failed to do, leading to a dismissal for failure to prosecute. This dismissal was reversed by the Court of Appeals, ordering the trial court to proceed. The case returned to the trial court, but the municipal mayor showed reluctance to prosecute, even requesting withdrawal, which the Municipal Council refused. Procedural History: Defendants again filed a motion to dismiss, reiterating the jurisdictional challenge. Petitioner, Barangay Matictic, filed a motion for intervention. The respondent judge took notice of the intervention motion and denied the motion to dismiss pending consideration of the intervention. On May 12, 1978, the respondent judge dismissed the expropriation case without prejudice, citing the lack of Presidential approval at the time of the initial filing. A motion for reconsideration was denied. The Municipality of Norzagaray did not appeal this dismissal, rendering it final. The Petition: Petitioner, Barangay Matictic, filed a petition for certiorari and mandamus, complaining that the respondent judge failed to rule on its motion for intervention, thus denying it personality to participate in the case. It sought to compel the judge to admit its complaint in intervention. This Court issued a temporary restraining order.
Issue(s)
Whether the respondent judge acted with grave abuse of discretion in dismissing the expropriation case without ruling on the motion for intervention. Whether the Barangay Matictic has the legal personality to question the dismissal of the expropriation case filed by the Municipality of Norzagaray.
Ruling
The petition is DENIED for lack of merit. The temporary restraining order issued is lifted and dissolved.
Ratio Decidendi
On the issue of whether the respondent judge acted with grave abuse of discretion in dismissing the expropriation case without ruling on the motion for intervention: The petition is manifestly untenable. The proper party to appeal or seek review of the dismissal of the expropriation proceedings would be the Municipality of Norzagaray, the original plaintiff. Petitioner Barangay Matictic, being a different political entity, lacks the legal personality to question these orders by itself, as it cannot continue the expropriation case independently. Since the Municipality of Norzagaray did not appeal the dismissal, the expropriation case became final and ceased to exist. Consequently, there is no longer a proceeding in which Barangay Matictic may intervene. An intervention is merely collateral or accessory to the principal action and is dependent on it; with the final dismissal of the original action, the complaint in intervention can no longer be acted upon. The dismissal of the expropriation case inherently carries the dismissal of the motion for intervention as an unavoidable consequence. On the issue of whether Barangay Matictic has the legal personality to question the dismissal of the expropriation case filed by the Municipality of Norzagaray: The petitioner, Barangay Matictic, has no legal personality to question the orders of dismissal because it may not, by itself, continue the expropriation case. The Municipality of Norzagaray, the plaintiff in the expropriation case, did not appeal the dismissal, making it final. Therefore, the expropriation case ceased to exist, and there is no longer a proceeding wherein Barangay Matictic could intervene. The right of an intervenor is merely in aid of the right of the original party; if the original party's right has ceased to exist, there is nothing to aid or fight for, and thus the right of intervention ceases to exist. It would be illogical and of no useful purpose to grant or consider the prayer to compel the lower court to admit the complaint in intervention. The dismissal of the expropriation case has the inherent effect of also dismissing the motion for intervention.
Main Doctrine
A motion for intervention, being accessory to the principal action, cannot be acted upon if the principal action has been finally dismissed. The dismissal of the original action inherently carries the dismissal of the motion for intervention.