G.R. No. 100468 - Laureano Investment and Development Corp. vs. Court of Appeals

Spouses Reynaldo Laureano and Florence Laureano, majority stockholders of petitioner Laureano Investment and Development Corporation, entered into various loan and credit transactions with Philippine National Cooperative Bank (PNCB).
To secure loans, the spouses executed Deeds of Real Estate Mortgage from 1962 to 1964 for multiple amounts.
Upon their failure to pay, PNCB filed for extrajudicial foreclosure and purchased the foreclosed properties, consolidating titles in its name in 1984.
PNCB did not obtain a writ of possession nor file ejectment due to pending cases challenging ownership of the two lots located at Bel-Air Subdivision, Makati.

Bormaheco, Inc. succeeded PNCB’s interest in the properties after a bulk sale in 1988, acquiring titles to Lot Nos. 4 and 5, Block 4, Bel-Air Village.
Five days after securing titles, Bormaheco filed an ex-parte petition for issuance of writ of possession over the lots.
Petitioner corporation filed a Motion for Intervention and attached a Complaint in Intervention, representing itself as "Lideco Corporation."
The RTC initially allowed intervention, finding prima facie interest of intervenor Lideco Corporation in dispute, to avoid multiplicity of suits.

Bormaheco moved to strike out the complaint in intervention, arguing Lideco Corporation did not have personality to intervene.
RTC ruled that "Lideco Corporation" and Laureano Investment and Development Corporation are separate and distinct entities.
Evidence showed Lideco Corporation was not registered with the Securities and Exchange Commission (SEC).
The documents supporting intervention (tax declarations) were in the name of Laureano Investment and Development Corporation, not Lideco Corporation.
The motion to strike out was granted; all pleadings filed by Lideco Corporation were expunged.

Petitioner moved to substitute itself in place of Lideco Corporation as party-intervenor and to adopt the complaint and pleadings.
RTC denied the motion, noting:

The tax declarations referred to different lots (Lot 3) than those subject to the writ of possession (Lots 4 and 5).
The tax declarations were canceled years before Bormaheco’s purchase.
The proposed substitution did not fall under exceptions authorized by Rule 3, Sec. 20 of the Rules of Court.

Petitioner contended Bormaheco is estopped from denying that Lideco Corporation and Laureano Investment and Development Corporation are the same, pointing to prior use of “LIDECO” as acronym by Bormaheco.
Petitioner also alleged bad faith by Bormaheco in filing the motion to strike out.
Bormaheco argued that Lideco Corporation lacks juridical personality, capacity to sue, and real interest in the action.
Bormaheco claimed the intervention attempt was a furtherance of the Laureano spouses’ efforts to prevent rightful ownership enforcement by subsequent owners.
Bormaheco moved to declare petitioner guilty of forum shopping citing numerous related litigations commenced by the Laureano spouses over the same properties.

RTC and Court of Appeals upheld denial of intervention and motions to strike out, finding:

Lideco Corporation was not a registered corporation.
No showing petitioner had legal interest in the properties subject of the petition.
Petitioner did not show that the tax declarations related to disputed properties.

Whether respondent Bormaheco, Inc. is estopped from denying the legal personality to sue of "Lideco Corporation."
Whether bad faith attended the filing of Bormaheco’s motion to strike out the complaint in intervention and related pleadings.