Case Digest (G.R. No. 125302)
Facts:
The case involves Lorenza Ortega as the petitioner and the Honorable Court of Appeals, Carmen Bascon Tibajia, and Norberto Tibajia, Jr. as respondents. The events leading to this case began on November 25, 1983, when Felipe L. Abel filed a complaint against the spouses Carmen Bascon Tibajia and Norberto Tibajia, Jr. to recover P250,000.00, which Carmen had obtained from him, along with claims for moral and actual damages, attorney's fees, and costs. Following the filing of the complaint, a writ of preliminary attachment was issued, leading to the attachment of the defendants' properties. The defendants failed to file an answer, resulting in their default on April 2, 1984, allowing the plaintiff to present evidence ex-parte. Felipe Abel passed away on April 25, 1984, and his heirs were substituted as plaintiffs on July 30, 1984.
On January 24, 1985, the trial court rendered a judgment in favor of the heirs, ordering the defendants to pay the principal sum of P250,00...
Case Digest (G.R. No. 125302)
Facts:
Background of the Case
- On November 25, 1983, Felipe L. Abel filed a complaint against spouses Carmen Bascon Tibajia and Norberto Tibajia, Jr. to recover P250,000.00, plus damages, attorney's fees, and costs.
- A writ of preliminary attachment was issued, and the defendants' properties were attached and levied.
- The defendants failed to file an answer and were declared in default on April 2, 1984.
- Felipe Abel died on April 25, 1984, before presenting evidence. His heirs were substituted as plaintiffs on July 30, 1984.
Judgment and Execution
- On January 24, 1985, the trial court rendered judgment in favor of the plaintiffs, ordering the defendants to pay P250,000.00 with interest, P50,000.00 as moral damages, and P10,000.00 as attorney's fees.
- The decision was published in a newspaper of general circulation after the defendants could not be located.
- The plaintiffs' heirs assigned their rights to Eden Tan, who filed for execution of the judgment.
- On December 17, 1985, the defendants' properties were sold at public auction to Lorenza Ortega for P448,989.50, satisfying the judgment debt.
Redemption and Dispute Over Costs
- On December 22, 1986, the defendants tendered P457,415.65 as redemption price, including charges.
- The defendants contested the bill of costs submitted by Eden Tan, claiming that certain expenses were inflated and unauthorized.
- The trial court found that some expenses were indeed bloated and adjusted the redemption price to P441,797.76, ordering a refund of P15,617.89 to the defendants.
Appeal to the Court of Appeals
- Eden Tan and Lorenza Ortega appealed the trial court's order to the Court of Appeals.
- The Court of Appeals dismissed the appeal, holding that neither Eden Tan nor Lorenza Ortega had locus standi (legal standing) to appeal, as they were not formal parties to the case.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Locus Standi: Only parties to a case have the right to appeal. Lorenza Ortega was not a formal party and had not filed a motion for intervention, which is required to become a party in interest.
- Intervention Requirements: Under the Rules of Court, a person seeking to intervene must have a legal interest in the matter in litigation and file a motion for leave to intervene. Lorenza Ortega failed to meet these requirements.
- Procedural Rules: Procedural rules are mandatory and must be followed. Non-compliance cannot be excused even if it results in injustice, unless there are compelling reasons to relax the rules.
- Redemption Price: The trial court correctly adjusted the redemption price after finding that certain expenses in the bill of costs were inflated and unauthorized.
Conclusion:
The Supreme Court upheld the dismissal of the appeal, emphasizing the importance of adhering to procedural rules and the necessity of having locus standi to participate in legal proceedings. Lorenza Ortega's failure to formally intervene in the case barred her from appealing the trial court's order.