Title
Mijares vs. Piccio
Case
G.R. No. L-10458
Decision Date
Apr 22, 1957
A wife sought annulment of deeds involving properties in separate provinces; Supreme Court ruled misjoinder of causes and improper venue, dismissing claims against some defendants.

Case Digest (G.R. No. 217972)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Vicente Mijares and Sulpicia Guanzon are petitioners in a proceeding for prohibition and certiorari with a preliminary injunction.
    • The petition seeks to enjoin respondent Judge Edmundo S. Piccio from enforcing his order directing the petitioners to answer a complaint and proceed with a trial in Civil Case No. R-3822, and at the same time, to set aside that order and dismiss the case as it affects them.
  • Origin of the Underlying Complaint
    • On December 24, 1954, Pastora Alvarez Guanzon initiated a civil action in the Court of First Instance of Cebu against her husband, Jose M. Guanzon.
    • The complaint contained two causes of action:
      • The first cause of action sought the annulment of two instruments:
        • A deed of sale executed in favor of Sulpicia Guanzon pertaining to certain real properties in Negros Occidental.
ii. A deed of donation inter vivos executed in favor of Joven Salvador Guanzon pertaining to another set of real properties in Cebu.
  • The second cause of action involved a claim for the separation of conjugal properties, which included both real and personal property acquired during the marriage (this was filed under a separate case number, R-3823).
  • Joinder of Parties and Subsequent Filings
    • On October 19, 1955, a motion was filed to join Sulpicia Guanzon and Vicente Mijares as defendant parties in the underlying complaint, on the ground that their presence was indispensable.
    • The motion was granted, and the defendants were duly summoned in accordance with law.
    • Instead of filing an answer, the newly joined defendants (petitioners) on January 17, 1956, filed a motion to dismiss based on three grounds:
      • Improper venue.
      • Misjoinder of causes of action and of parties defendants.
      • Lack of jurisdiction over their persons.
  • Proceedings in the Lower Court
    • After considering the motion to dismiss, the Court of First Instance denied it on February 7, 1956.
      • The court ruled that the case was in personam as it did not affect title to real property.
      • It held that there was no misjoinder of causes of action.
      • It affirmed its jurisdiction over the personalities of the petitioners.
    • The petitioners then filed a motion for reconsideration, which was subsequently denied.
    • Following the denial, the petitioners elevated the matter by interposing the present petition for prohibition and certiorari seeking to set aside the orders dated February 7, 1956, and March 5, 1956.
  • Legal Framework Addressed
    • The case involves the application of Rule 2, Section 5 which allows for the joinder of several causes of action, counterclaims, cross-claims, and third-party claims in one complaint, provided that the rules regarding venue and joinder of parties are observed.
    • Difficulties in applying the rule may arise because it does not specifically enumerate the instances in which several causes of action may be joined, with each case possibly depending on the nature of the transactions involved.
    • Former Chief Justice Moran’s illustrations on the limitations imposed by venue and joinder of parties are referenced to underscore these difficulties.
  • Identification of Misjoinder
    • The petitioners argued that there was a misjoinder on two counts:
      • Venue Issue
        • The annulment of the deed of sale relates to properties in Negros Occidental, while the annulment of the deed of donation relates to properties in Cebu.
ii. The difference in location implies that the venue is improperly laid for the properties in Negros Occidental.
  • Parties Issue
    • The deed of sale was in favor of Sulpicia Guanzon and the deed of donation in favor of Joven Salvador Guanzon.
ii. There was no indication of a common interest among the defendants that would justify joining them in a single cause of action, as their interests in the distinct transactions were separate.

Issues:

  • Whether the joinder of separate causes of action—one involving real properties in Negros Occidental and the other involving properties in Cebu—in a single complaint is proper given the venue limitations dictated by law.
  • Whether the inclusion of distinct parties with separate and non-overlapping interests in the same cause of action constitutes a misjoinder in violation of the rules on the joinder of parties.
  • Whether the lower court erred in dismissing the petitioners’ motion to dismiss on the grounds of improper venue and misjoinder.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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