Case Digest (G.R. No. 58168) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Concepcion Magsaysay-Labrador et al. v. Court of Appeals and Adelaida Rodriguez-Magsaysay, decided December 19, 1989, petitioners Concepcion Magsaysay-Labrador, Soledad Magsaysay-Cabrera, Luisa Magsaysay-Corpuz (assisted by Dr. Jose Corpuz), Felicidad P. Magsaysay, and Mercedes Magsaysay-Diaz moved to intervene in an annulment suit initiated on February 9, 1979 by Adelaida Rodriguez-Magsaysay, widow and special administratrix of the estate of the late Senator Genaro F. Magsaysay, before the Court of First Instance (CFI) of Olongapo City. Respondent alleged that the conjugal parcel “Pequena Island” (TCT No. 3258), acquired in 1958, was wrongfully annotated as separate property, then assigned to Subic Land Corporation (SUBIC) via a Deed of Assignment (June 25, 1976) resulting in cancellation of TCT No. 3258 and issuance of TCT No. 22431 in SUBIC’s name, and further mortgaged to Filipinas Manufacturer’s Bank (April 28, 1977) without her consent. Petitioners claimed they became a Case Digest (G.R. No. 58168) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Adelaida Rodriguez-Magsaysay, widow and special administratrix of the estate of the late Senator Genaro F. Magsaysay, filed on February 9, 1979 an action in the Court of First Instance (CFI) of Olongapo City against:
- Artemio Panganiban
- Subic Land Corporation (SUBIC)
- Filipinas Manufacturer’s Bank (FILMANBANK)
- Register of Deeds of Zambales
- She sought annulment of:
- A Deed of Assignment (June 25, 1976) transferring “Pequeña Island” (TCT No. 3258) from her late husband to SUBIC (resulting in TCT No. 22431 in SUBIC’s name)
- A Deed of Mortgage (April 28, 1977) by SUBIC in favor of FILMANBANK for ₱2,700,000
- Allegations and Relief Sought
- The land was acquired with conjugal funds; the annotation on TCT No. 3258 and subsequent transfer were void for lack of marital consent, Commissioner approval, and due to fraud, mistake, violence or intimidation.
- The Deed of Assignment was without consideration and therefore null and void.
- Prayer: annul the Assignment and Mortgage; cancel TCT No. 22431; reissue title in her name.
- Petitioners’ Motion to Intervene
- On March 7, 1979, petitioners (sisters of the late senator) moved to intervene, claiming they acquired by Deed of Sale dated June 20, 1978 one-half of his SUBIC shares (416,566.6 shares, ~41% of outstanding capital stock).
- They argued this stake gave them a substantial legal interest in the litigation’s subject matter.
- Lower Court and Appellate Rulings
- CFI denied intervention on July 26, 1979: petitioners had no legal interest and could pursue their claims in separate proceedings.
- Court of Appeals affirmed on July 13, 1981; denied motion for reconsideration on September 7, 1981.
- Related pending cases protecting petitioners’ interests:
- Special Proceedings No. 122122 (CFI Manila): validity of share transfer to petitioners
- Civil Case No. 2577-O (CFI Zambales): annulment suit with petitioners as attempted intervenors
- SEC Case No. 001770: stockholder adjudication; petitioners’ intervention eventually allowed
- SP No. Q-26739 (CFI Rizal): contingent claim by petitioners
- Supreme Court Review
- Petitioners sought certiorari to reverse the denial of intervention, raising the purely legal question whether they had a legal interest under Section 2, Rule 12 of the Revised Rules of Court.
Issues:
- Whether petitioners, as alleged assignees of 41.66% of SUBIC’s capital stock, had a direct legal interest in the subject matter of Adelaida Rodriguez-Magsaysay’s annulment suit sufficient to intervene under Section 2, Rule 12 of the Revised Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)