G.R. No. 223572 - Eo-Bote vs. Alvarez

The case involves a 463-square meter parcel of land covered by Transfer Certificate of Title (TCT) No. 41860, originally in the name of Flaviana De Gracia.
Upon Flaviana’s death in 1980 (intestate), her half-sisters, Hilaria Martin-Paguyo and Elena Martin-Alvarado, became her compulsory heirs.
In September 1982, through a private document entitled "Tapno Maamoan ti Sangalobongan," Hilaria and Elena waived all hereditary rights in favor of Francisca Medrano as consideration for expenses incurred for Flaviana’s medication, hospitalization, wake, and burial.
Following the waiver, Medrano constructed a concrete bungalow on the property without any objections from the original heirs or their children.
After the deaths of Hilaria and Elena, some of their children confirmed the contents of the private document by separately executing deeds of confirmation and renunciation of rights in favor of Medrano, thereby affirming her continuous possession of the property.

Due to the refusal of a number of the heirs’ children to execute a similar renunciation, Medrano initiated litigation on April 27, 2001, filing a Complaint for quieting of title, reconveyance, reformation of instrument, and/or partition with damages in Civil Case No. U-7316 at the RTC of Urdaneta, Pangasinan.
Medrano also caused the annotation of a notice of lis pendens on the subject TCT on May 3, 2001.
An Amended Complaint was subsequently filed on August 29, 2001, which expanded the list of defendants after the death of one of the parties.
Summons for the original complaint were served upon some defendants; however, service with respect to the amended complaint was not extended to all original parties.

On April 2, 2002, respondent Estanislao D. De Vera filed an Answer with Counterclaim, presenting himself as the transferee pendente lite based on a quitclaim executed in his favor by some of the defendants.
De Vera contended that the "Tapno Maamoan ti Sangalobongan" was null and void for want of adequate consideration, thereby asserting that the waiver and subsequent possession by Medrano should not affect his interest acquired from the defendants.
Medrano moved to expunge De Vera’s Answer with Counterclaim and declared the named defendants in default. The trial court, however, admitted De Vera’s answer, opining that as a transferee pendente lite he did not require special power of attorney to answer in his own behalf and that his interest could not be treated separately from that of his transferors.
As the proceedings advanced, Medrano presented her evidence ex parte against the defaulting defendants, despite the unresolved issue of De Vera’s proper joinder or substitution under Rule 19 of the Rules of Court.

In its Decision rendered on April 21, 2003, the RTC ruled that Medrano’s title had vested by virtue of her good-faith possession for more than ten years. The court also held that the private document ("Tapno Maamoan ti Sangalobongan") sufficiently conveyed the property.
The RTC ordered the cancellation of TCT No. 41860 and the issuance of a new title in Medrano’s name, thereby deciding the dispute in her favor.
De Vera filed motions for reconsideration and later a Manifestation expressing his intention to seek certiorari and mandamus before the Court of Appeals to remedy his procedural exclusion, arguing that his rights as a transferee pendente lite were compromised.
The trial court’s approach allowed Medrano’s ex parte presentation of evidence against the defaulting named defendants even though De Vera had already been admitted as a party through his answer. This separation of interests and the failure to properly join De Vera set the stage for appellate review.

Whether respondent De Vera could validly participate in Civil Case No. U-7316 without filing a motion to intervene, given his status as a transferee pendente lite of the defaulting defendants.
Whether De Vera, as a transferee pendente lite whose rights were acquired from the original defendants, is bound by the judgment rendered against his transferors.
Whether the Court of Appeals was correct in taking cognizance of respondent’s petition for certiorari and mandamus on the ground that the trial court improperly allowed ex parte presentation of evidence and failed to properly join De Vera as a party-defendant.