Pulgar v. Quezon Power
REITERATIONFacts
The Antecedents: Sometime in 1999, the Municipal Assessor of Mauban, Quezon issued 34 tax declarations on the buildings and machinery of Quezon Power (Philippines) Limited, Co.'s (QPL) Mauban Plant, assessing a total market value of P29,626,578,291.00, resulting in annual realty taxes of approximately P500 Million. QPL filed a sworn statement on May 18, 2000, declaring a lower value of P15,055,951,378.00. On March 16 and 23, 2001, QPL tendered P60,223,805.51 as a first quarter installment of realty taxes, which the Municipal Assessor rejected. QPL filed a Complaint for Consignation and Damages before the Regional Trial Court (RTC) of Mauban, Quezon, Branch 64, depositing the tendered amount as payment for the first quarter realty tax for 2001. Although classified as a consignation and damages case, QPL essentially protested the Municipal Assessor's assessment, questioning its legal authority and compliance with valuation processes. The defendants averred that QPL was estopped from denying the Municipal Assessor's authority as it had previously paid realty taxes for 2001 based on the same assessment. Procedural History: On January 28, 2002, Frumencio E. Pulgar (Pulgar), a resident and taxpayer of Quezon Province, filed a Motion for Leave to Admit Answer-in-Intervention and Answer-in-Intervention, asserting his interest in the aggressive collection of realty taxes against QPL and seeking moral damages and attorney's fees for environmental disturbance. Pulgar's motion was initially granted, and his Answer-in-Intervention was admitted. In June 2002, QPL and the Province of Quezon agreed to submit their dispute to the Secretary of Finance, who issued a Resolution on August 30, 2002, passing upon the basic issues between the parties. In an Order dated December 2, 2002, the RTC dismissed Civil Case No. 0587-M for lack of jurisdiction, finding that QPL's complaint essentially challenged the assessed tax amount, which should have been brought before the Local Board of Assessment Appeals. The RTC ruled that the requirement of payment of the tax assessed under protest was not met. Consequently, the RTC also dismissed Pulgar's motion for intervention. Pulgar filed a motion for reconsideration, which was denied in an Order dated March 13, 2003. The Petition: Pulgar filed a petition for review on Certiorari assailing the RTC's Orders dated December 2, 2002, and March 13, 2003, which dismissed Civil Case No. 0587-M and his motion for intervention on jurisdictional grounds. Pulgar acknowledged the RTC's lack of jurisdiction but prayed that the Court pass upon the correctness of the Municipal Assessor's assessment of QPL's realty taxes.
Issue(s)
Whether the Regional Trial Court (RTC) correctly dismissed the motion for intervention as a necessary consequence of the dismissal of the main action for lack of jurisdiction.
Ruling
The petition is denied. The Regional Trial Court did not err in dismissing the motion for intervention as a consequence of the dismissal of the main case for lack of jurisdiction.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Regional Trial Court (RTC) did not err in dismissing the intervention because jurisdiction over an intervention is governed by jurisdiction over the main action. Applying the precedent in Asian Terminals, Inc. v. Judge Bautista-Ricafort, the Court clarified that an intervention necessarily presupposes the pendency of a suit in a court of competent jurisdiction. Since the RTC's lack of jurisdiction over the main case (due to Quezon Power (Philippines) Limited, Co.'s [QPL] failure to pay the tax under protest) was uncontested, the principal litigation ceased to exist. The Court emphasized that intervention is never an independent action but is merely ancillary and supplemental to existing litigation, designed to aid an original party. Relying on the doctrine in Cariño v. Ofilada, the Court reiterated that where the right of the original party has ceased to exist, there is nothing left to aid or fight for, and the right of intervention ceases as a matter of course. Therefore, Pulgar could not maintain his intervention as a standalone request for review of the tax assessment once the main case was dismissed on jurisdictional grounds.
Main Doctrine
Jurisdiction over an intervention is governed by jurisdiction over the main action; an intervention presupposes the pendency of a suit in a court of competent jurisdiction. If the main case is dismissed for lack of jurisdiction, the intervention necessarily follows.