G.R. No. 175352 - Liban vs. Gordon

The case originates from a partition action involving the estate of the late Mateo Clidoro.
The original partition case was resolved in Civil Case No. T-98 with a decision issued on March 10, 1988 by the RTC and later affirmed with modifications by the Court of Appeals (CA) in CA-G.R. CV No. 19831 dated November 13, 1995.
The CA judgment partitioned the estate into specific shares:

One-fifth portion to the plaintiffs-appellees with representation of Gregorio Clidoro, Sr.’s hereditary share.
One-fifth portion to Defendant-Appellant Antonio Clidoro or his legal heirs.
One-fifth portion to Appellant Josaphat Clidoro.
One-fifth portion to Appellant Aida Clidoro.
One-tenth portion to Gregoria Clidoro, representing her legitime in the hereditary share of Onofre Clidoro.
One-tenth portion to Catalino Morate, as successor-in-interest to the legitime of Consorcia Clidoro.

Following the partition decision, a separate complaint was filed (Civil Case No. T-2275) for the revival of judgment, which sought the execution of the CA decision in the partition case.
The complaint for revival of judgment alleged that the prevailing parties in the partition case had the right to enforce the judgment through revival, even though some of the parties in the pleading differed from those in the original case.
The complaint was brought by Rizalina Clidoro (and others) against Onofre Clidoro (and others), with parties clearly identified as plaintiffs, defendants, and interested parties.
Though the complaint made reference to the fact that some parties were deceased or represented by others, it aimed to secure the execution of the partition decision based on the alleged rights of the prevailing parties.

On September 3, 2003, defendants-appellees (except Gregoria Clidoro-Palanca) filed a motion to dismiss the complaint on several grounds:

The complaint was argued to be defective as it lacked the real parties-in-interest, being brought against or by parties who no longer existed in a material sense due to death.
Allegations were made that there was an improper substitution of parties, not in conformity with procedural rules.
The motion also contended that even if revived, the decision could not be executed because the requirements under Rule 69, Section 3 of the 1997 Rules of Civil Procedure had not been met.
It was further argued that the partition judgment was interlocutory, leaving further matters unsettled and thus not ripe for execution.

The RTC, after receiving comments, oppositions, and rejoinders from the parties, issued an Order on December 8, 2003 dismissing the complaint for lack of cause of action.

The RTC's order emphasized that many of the parties already lacked a natural or material existence and that the complaint did not properly identify the real parties-in-interest.
It was noted that some parties in the complaint were not the original parties to the partition action but merely represented them.

Plaintiffs-appellants subsequently moved for reconsideration by filing an amended complaint, which sought to implead additional heirs and original plaintiffs.

On October 17, 2006, the CA reversed the RTC's dismissal and remanded the case back to the RTC for further proceedings.
A motion for reconsideration of the CA decision was also filed by the petitioners but was denied via a CA Resolution on February 6, 2007.

The petition for review on certiorari was ultimately raised before the Supreme Court, with the petition raising several issues regarding the substitution of parties and the sufficiency of the complaint.

Plaintiffs – including representatives for deceased parties and individuals continuing the interests recognized in the partition case.
Defendants – individuals purportedly representing the corresponding balances of the partition decision.
Interested parties – additional heirs or successors representing the original parties’ interests.

A comparison between the parties named in the original partition action and those in the revival complaint showed substantial overlap, though with differences in nomenclature due to representation or the death of some original parties.
The determination of whether the parties in the revival complaint were the "real parties-in-interest" became a central factual and legal point in the proceedings.

Whether the complaint for revival of judgment may be dismissed for lack of cause of action on the ground that it was not brought by or against the real parties-in-interest.

Whether the selection and substitution of parties in the complaint were correct and in compliance with procedural rules.
Whether the apparent misjoinder of parties in the revival action undermines the ability of the plaintiff(s) to secure execution of the partition judgment.

Whether the amendment to the pleadings, which included additional heirs and original parties, was properly effected and applicable to the instant action.

Whether the inclusion of representations for deceased original parties suffices to establish real party-in-interest status.
Whether the complaint, even with changes in the names of the parties, still meets the threshold requirement of stating a valid cause of action.

Whether the issue raised regarding the interlocutory nature of the partition judgment affects the enforceability of the original decision through a revival action.

The scrutiny under Rule 16 of the Rules of Court regarding dismissal for failure to state a cause of action.