G.R. No. 204222 - Neptune Metal Scrap Recycling, Inc. vs. Manila Electric Co.

On August 10, 2010, Rolando Flores and Jhannery Hupa, the accused, were driving a trailer truck with a container van towards the Manila International Container Port.
Men from the Criminal Investigation and Detection Group flagged the vehicle on suspicion that it was illegally transporting electric power transmission scrap copper wires owned by Meralco.
The police seized the truck along with its contents and detained the accused.
The accused were charged before the Regional Trial Court (RTC) of Malabon with theft of electric power transmission lines and materials under Section 3 of Republic Act No. 7832 (Criminal Case No. 10-1419).

Neptune Metal Scrap Recycling, Inc. (Neptune) traced its roots to the criminal case, asserting that it owned the contents of the container van.
Neptune claimed ownership of thirteen bundles of scrap copper wires valued at approximately ₱8,000,000.00.
In support of its claim, Neptune presented several documents including a purchase order from Trumet International, its Export Declaration to the Department of Trade and Industry, and a packing list.

Neptune filed an entry of special appearance with a motion for leave to inspect, examine, and photograph the container van and its contents.
The RTC granted Neptune’s motion, ordering an initial ocular inspection and a subsequent inspection during which Meralco’s representatives also inspected the container van.
Neptune actively participated in the proceedings by submitting multiple pleadings:

A manifestation on the results of the first inspection;
A motion to deposit the keys to the container van with the court and its supplement;
A memorandum of authorities on “birch cliff copper”;
A manifestation on the results of the second inspection;
A motion for the release of the goods; and
A comment regarding Meralco’s compliance.

During a clarificatory hearing, the RTC observed that no Meralco power transmission scrap copper wires were found, and on January 3, 2011, it ordered the quashal of the information.
The RTC ordered the return of the keys and the container van to Neptune, which subsequently recovered three remaining bundles of scrap copper wires.
Meralco filed a motion for reconsideration, which was denied by the RTC, and then petitioned for certiorari before the Court of Appeals (CA) without including Neptune as a party.

Neptune filed a motion for leave to intervene and to admit its comment-in-intervention in the CA proceedings.
Meralco opposed Neptune’s motion on two primary grounds:

Arguing that the subject matter—electric power transmission scrap copper wires—is distinct from the "birch cliff copper" wires claimed by Neptune;
Asserting that Neptune’s intervention was untimely and lacked legal interest.

Neptune failed to demonstrate its legal interest in the subject matter;
Allowing the intervention would unduly delay or prejudice the adjudication of the case; and
Neptune’s motion was not timely filed, as it was not submitted before the RTC rendered its judgment.

The CA further denied Neptune’s motion for reconsideration, prompting the petition for review.

Whether Neptune has a sufficient legal interest in the subject matter of the proceedings, particularly concerning the scrap copper wires contained in the seized container van.

Does Neptune’s claim of ownership over the "birch cliff copper" scrap, which encompasses the transmission wires allegedly belonging to Meralco, qualify as a direct legal interest?

Whether the entry with motion filed by Neptune, though not expressly labeled as a “motion for intervention,” effectively satisfies the procedural requirements for intervention under Rule 19 of the Rules of Court.
Whether granting Neptune’s intervention would unduly delay or prejudice the adjudication of the rights of the accused and the State, or if its rights could be adequately protected in a separate proceeding.
Whether the procedural rules on intervention should be applied flexibly to promote substantial justice, despite technical deficiencies in the filing.