Title
Baldo vs. Guerrero
Case
G.R. No. L-15593
Decision Date
Nov 29, 1960
Plaintiffs sought land recovery, alleging defendants unlawfully took possession in 1954. Lower court dismissed due to misjoinder; Supreme Court reversed, ruling joinder proper under Rule 3, Section 6, and remanded.
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Case Digest (G.R. No. L-15593)

Facts:

Parties Involved

  • Plaintiffs-Appellants: Maria Baldo, Feliciana Blanco, Marcelo Blanco, Isabelo Blanco, Francisco Abrajano, Braulio Abrajano, Enrica Abrajano, Benjamin Abrajano, Julita Abrajano, and Apolonio Farrales.
  • Defendants-Appellees: Pedro Guerrero and others.

Subject Matter

The plaintiffs sought to recover possession and ownership of several parcels of land. Each plaintiff claimed ownership over specific parcels:

  • Maria Baldo claimed ownership of the first and second parcels.
  • Feliciana, Marcelo, and Isabelo Blanco claimed ownership of the third parcel.
  • Francisco, Braulio, Enrica, Benjamin, and Julita Abrajano claimed ownership of the fourth, fifth, and sixth parcels.
  • Apolonio Farrales claimed ownership of the seventh and eighth parcels.

Allegations

The plaintiffs alleged that in March and April 1954, the defendants unlawfully fenced off and took possession of the properties, excluding the plaintiffs from their use and enjoyment.

Procedural History

  • The plaintiffs filed a complaint on September 14, 1958.
  • The defendants filed a motion to correct misjoinder and nonjoinder of parties on February 25, 1959, arguing that the plaintiffs should file separate complaints for each cause of action and include the Director of Lands as an indispensable party.
  • The lower court dismissed the complaint on March 20, 1959, without prejudice to the plaintiffs filing separate actions.
  • The plaintiffs' motion for reconsideration was denied on April 2, 1959.
  • The plaintiffs appealed the dismissal to the Supreme Court.

Issue:

  1. Whether the lower court erred in dismissing the complaint due to misjoinder and nonjoinder of parties.
  2. Whether the joinder of plaintiffs in a single complaint was proper under the Rules of Court.
  3. Whether the Director of Lands should have been included as a co-defendant.

Ruling:

The Supreme Court reversed the lower court's orders and remanded the case for further proceedings. The Court held that the joinder of plaintiffs was proper under Section 6, Rule 3 of the Rules of Court, as the plaintiffs' claims arose from the same series of transactions and involved common questions of law and fact. The Court also ruled that the nonjoinder of the Director of Lands was not a ground for dismissal, as the lower court could have ordered his inclusion without dismissing the case.

Ratio:

  1. Joinder of Parties: Under Section 6, Rule 3 of the Rules of Court, parties may be joined in a single complaint if their claims arise from the same transaction or series of transactions and involve common questions of law or fact. The plaintiffs' claims met this requirement, as they all alleged unlawful deprivation of their properties by the defendants in March and April 1954.
  2. Misjoinder and Nonjoinder: Misjoinder or nonjoinder of parties is not a ground for dismissal. The court has the authority to drop or add parties at any stage of the proceedings. The lower court erred in dismissing the complaint instead of ordering the inclusion of the Director of Lands if deemed necessary.
  3. Judicial Efficiency: The joinder of plaintiffs serves to avoid a multiplicity of suits, prevent inconsistent verdicts, save public resources, and protect defendants from repeated litigation on the same issue. The lower court's dismissal, even if without prejudice, was improper and final in character, necessitating reversal.

Conclusion:

The Supreme Court ruled in favor of the plaintiffs, holding that the joinder of parties was proper and that the lower court erred in dismissing the complaint. The case was remanded for further proceedings, with costs against the defendants-appellees.


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