Mendoza v. Coronel
REITERATIONFacts
The Antecedents: Spouses Alfredo and Rosario Mendoza (petitioners) occupied Lots 3250 and 3251, owned by Maria Coronel (respondent) and her co-owners, based on their tolerance and without paying rent. When respondent demanded they vacate, petitioners refused. Procedural History: Respondent filed an unlawful detainer case against petitioners before the Municipal Trial Court (MTC) of Hagonoy, Bulacan. The MTC ruled in favor of the respondent. Petitioners appealed to the Regional Trial Court (RTC) of Malolos, Bulacan, which annulled the MTC decision, holding that the co-owners were indispensable parties who were not impleaded. On appeal to the Court of Appeals (CA), the CA reversed the RTC decision, reinstated the MTC ruling, and denied petitioners' motion for reconsideration. The Petition: Petitioners appealed to the Supreme Court, assigning errors regarding the CA's ruling that a co-owner can bring an ejectment action without impleading co-owners, the authority of the attorney-in-fact, and the validity of the certification against forum-shopping executed by the attorney-in-fact.
Issue(s)
Whether a co-owner may bring an action in ejectment without impleading all other co-owners. Whether an attorney-in-fact of a co-owner needs the authority of all co-owners to file an ejectment suit. Whether a certification against forum-shopping executed by an attorney-in-fact is valid.
Ruling
The Supreme Court denied the appeal, affirming the Court of Appeals' decision which reversed the RTC and revived the MTC ruling. The Court held that the MTC had jurisdiction and that the ejectment case was validly filed.
Ratio Decidendi
On the issue of whether a co-owner may bring an action in ejectment without impleading all other co-owners: The Court reiterated the ruling in Arcelona v. Court of Appeals, emphasizing that Article 487 of the Civil Code explicitly states that "any one of the co-owners may bring an action in ejectment." This provision is a departure from previous jurisprudence, such as Palarca v. Baguisi, which required all co-owners to file the action. The Court explained that Article 487 allows a co-owner to initiate ejectment proceedings, which encompass various actions for recovery of possession, including unlawful detainer, without the necessity of joining all other co-owners as co-plaintiffs. This is because the suit is considered to be instituted for the benefit of all co-owners. The RTC's reliance on an uncorrected version of the Arcelona decision was deemed erroneous. On the issue of whether an attorney-in-fact of a co-owner needs the authority of all co-owners to file an ejectment suit: The Court rejected petitioners' argument. Given that Article 487 of the Civil Code permits any one co-owner to bring an ejectment action for the benefit of all, it follows that an attorney-in-fact acting for the plaintiff co-owner does not require authorization from all co-owners. The attorney-in-fact only needs the authority from the specific co-owner who is instituting the ejectment suit, as evidenced by a Special Power of Attorney. On the issue of whether a certification against forum-shopping executed by an attorney-in-fact is valid: The Court held that the execution of the certification against forum-shopping by the attorney-in-fact was valid. The attorney-in-fact, who was authorized to file the complaint and did so as the representative of the plaintiff co-owner, is considered a party to the ejectment suit. Section 1, Rule 70 of the Rules of Court includes the representative of the owner in an ejectment suit as one of the parties authorized to initiate the proceedings. Therefore, the attorney-in-fact's execution of the certification is permissible.
Main Doctrine
Under Article 487 of the Civil Code, any one of the co-owners may bring an action in ejectment, and such suit is deemed instituted for the benefit of all, without the necessity of joining all other co-owners as co-plaintiffs. Consequently, an attorney-in-fact of a co-owner instituting such an action only needs authority from the co-owner who is the plaintiff.