Facts:

The case involves Big Country Ranch Corporation (petitioner) against the Court of Appeals, Max B. Palarca, and Golden Flame Sawmill Corporation (respondents). The events leading to this case began on May 9, 1991, when Max B. Palarca filed a complaint in the Regional Trial Court of Manila, Branch 3, under Civil Case No. 91-57097, seeking the recovery of two barges named "Bangsi" and "Dangsol" from the possession of the First Coast Guard District, Philippine Coast Guard. Palarca sought a writ of replevin to reclaim these barges. On May 21, 1991, after Palarca posted a bond of P600,000.00 in favor of Golden Flame Sawmill Corporation (the defendant-intervenor), the court issued a writ of replevin for the seizure of the barges. However, the sheriff's report on May 27, 1991, indicated that the barges in custody were "BCRC I" and "BCRC II," which had different descriptions from the barges claimed by Palarca. To clarify the identities of th...

Facts:

Background of the Case

The case originated from an order issued by the Regional Trial Court (RTC) of Manila, Branch 3, on July 16, 1991, in Civil Case No. 91-57097, entitled "Max B. Palarca vs. Capt. Arturo Y. Capada, PN." The case involved a complaint filed by Max B. Palarca on May 9, 1991, seeking the recovery of two barges named "Bangsi" and "Dangsol" from the possession of the First Coast Guard District, Philippine Coast Guard. Palarca also sought the issuance of a writ of replevin for this purpose.

Writ of Replevin and Identification of Barges

On May 21, 1991, the RTC issued a writ of replevin after Palarca posted a bond of P600,000.00. The writ was executed in favor of Golden Flame Sawmill Corporation, which was allowed to intervene as a defendant. However, the implementing sheriff reported on May 27, 1991, that the barges in the custody of the Philippine Coast Guard were identified as "BCRC I" and "BCRC II," which allegedly had different descriptions from "Bangsi" and "Dangsol." To resolve the discrepancy, the trial court ordered a re-measurement of the barges by the Marine Surveyor of the Philippine Coast Guard.

Intervention by Golden Flame Sawmill Corporation

Golden Flame Sawmill Corporation filed an urgent motion for intervention, claiming ownership of the barges, which it allegedly acquired from Big Country Ranch Corporation (petitioner) in a public auction sale. The trial court allowed Golden Flame Sawmill to intervene on May 30, 1991.

Petitioner's Motion to Intervene

On July 8, 1991, Big Country Ranch Corporation filed a motion to intervene, asserting ownership of the barges based on xerox copies of documents issued by the Philippine Coast Guard. Golden Flame Sawmill opposed this motion. On July 16, 1991, the trial court denied petitioner's motion, stating that petitioner had no legal interest in the matter and that the intervention would unduly delay the case. The court also ordered the release of the barges to Palarca upon the security of the replevin bond.

Appeal to the Court of Appeals

Petitioner filed a petition for certiorari before the Court of Appeals, which dismissed the petition on August 30, 1991. Petitioner then appealed to the Supreme Court, challenging the denial of its motion to intervene and alleging grave abuse of discretion by the Court of Appeals.

Issue:

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Ruling:

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Ratio:

1. Intervention is Discretionary: The right to intervene is not absolute and is subject to the discretion of the court. The court must consider whether the intervention will unduly delay the case or prejudice the rights of the original parties.
2. Legal Interest Required: A party seeking to intervene must demonstrate a legal interest in the matter in litigation. In this case, the petitioner failed to show such an interest, especially since the barges had already been sold at a public auction to Golden Flame Sawmill Corporation.
3. Separate Remedy Available: The petitioner's claims, including allegations of irregularities in the public auction, could be better addressed in a separate proceeding. Allowing intervention in the replevin case would complicate the proceedings and delay the resolution of the original parties' claims.
4. Finality of Judgment: The Court noted that the main case had already been decided, and no appeal had been taken. Intervention is only permissible before or during trial, not after the case has been resolved.
5. No Grave Abuse of Discretion: The trial court's decision to deny intervention was based on rational grounds, and the Court of Appeals correctly affirmed this decision. There was no showing of grave abuse of discretion.