Case Digest (G.R. No. 58168)
Facts:
Concepcion Magsaysay-Labrador, Soledad Magsaysay-Cabrera, Luisa Magsaysay-Corpuz, assisted by her husband, Dr. Jose Corpuz, Felicidad P. Magsaysay, and Mercedes Magsaysay-Diaz v. The Court of Appeals and Adelaida Rodriguez-Magsaysay, Special Administratrix of the Estate of the Late Genaro F. Magsaysay, G.R. No. 58168, December 19, 1989, Supreme Court Third Division, Fernan, C.J., writing for the Court.
On February 9, 1979, Adelaida Rodriguez‑Magsaysay (widow and special administratrix of the estate of the late Senator Genaro Magsaysay) filed an action in the Court of First Instance (CFI) of Olongapo against Artemio Panganiban, Subic Land Corporation (SUBIC), Filipinas Manufacturer’s Bank (FILMANBANK) and the Register of Deeds of Zambales. She alleged that a parcel called “Pequena Island,” originally covered by TCT No. 3258 and acquired with conjugal funds, had been improperly annotated as acquired from the deceased’s separate capital, that a purported Deed of Assignment (June 25, 1976) transferred the title to SUBIC and resulted in issuance of TCT No. 22431 in SUBIC’s name, and that SUBIC later mortgaged the property to FILMANBANK; she sought annulment of the assignment and mortgage and cancellation of TCT No. 22431.
On March 7, 1979, petitioners (sisters of the late senator) moved to intervene, alleging that by a Deed of Sale dated June 20, 1978 their brother transferred to them one‑half of his SUBIC shareholdings (about 41.66% of outstanding stock), so they claimed a substantial legal interest in the litigation affecting SUBIC’s principal asset.
On July 26, 1979, the CFI denied the motion to intervene, holding that petitioners lacked a legal interest in the subject matter and that alleged status as assignees of shares did not permit intervention because a corporation is distinct from its stockholders. The Court of Appeals, in a decision dated July 13, 1981, affirmed the CFI’s ruling and, by resolution of September 7, 1981, denied petitioners’ motion for reconsideration. The Court of Appeals observed that petitioners could assert their claims in separate proceedings and were not left without remedy.
Petitioners sought review by the Supreme Court via a petition for review on certiorari (Rule 45), contending that their alleged acquisition of 41.66% of SUBIC’s outstanding capital stock vested them with such an interest in the corporate asset as to permit intervention; they invoked PNB v. Philippine Veget...(Subscriber-Only)
Issues:
- Did petitioners have a legal interest in the matter in litigation sufficient to entitle them to intervene under Section 2, Rule 12 of the Revised Rules of Court?
- If petitioners had such an interest, were their rights nevertheless adequately protectable in other proceedings so that denial of in...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)