Title
Lacuna vs. Board of Liquidators
Case
G.R. No. L-18621
Decision Date
Nov 28, 1964
The court ruled that an assignor who revokes a deed of assignment without consideration is an indispensable party, necessitating their intervention for a fair appeal review.
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Case Digest (G.R. No. L-18621)

Facts:

  • Salvador D. Lacuna is the petitioner against the Board of Liquidators, Pedro Q. Molina (Commanding General of the Philippine Air Force), and the Court of Appeals.
  • On September 11, 1953, Cirilo S. Damian was authorized by the Philippine Air Force (PAF) to repair its buildings in exchange for surplus properties.
  • Damian assigned his rights to the remaining surplus properties to Lacuna on September 23, 1955, and Lacuna notified the PAF of this assignment on September 24, 1955.
  • On June 14, 1956, Damian revoked the assignment, claiming Lacuna failed to meet his obligations, leading the PAF to inform Lacuna that it would not honor the assignment.
  • Lacuna filed a complaint for specific performance against the PAF and the Board of Liquidators, which was dismissed by the Court of First Instance of Manila and affirmed by the Court of Appeals.
  • Lacuna's petition for certiorari noted that Damian's motion to intervene was denied, raising concerns about the fairness of the proceedings.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that Cirilo S. Damian should be allowed to intervene as an indispensable party.
  • The Court ordered the remand of the records to the trial court to facilitate Damia...(Unlock)

Ratio:

  • The Supreme Court highlighted that Damian was an indispensable party because his rights and obligations were directly impacted by the case's outcome.
  • Excluding him wo...continue reading

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