Facts:
On May 3, 2007,
Haus Talk Project Managers, Inc. (HTPMI) and
spouses Ramon and Annabelle Sabado (
respondents) entered into a
Contract to Sell over a real property located at Lot 26, Block 1, Eastview Homes, Barangay Balimbing, Antipolo City (
subject property). Respondents paid HTPMI the total amount of
P869,400.00, composed of a
P174,400.00 downpayment and
P695,000.00 payable in
120 equal monthly installments. The contract stipulated that respondents’ failure to pay within the prescribed period would result in the forfeiture of the downpayment and other related payments, and the
cancellation and rescission of the Contract to Sell in accordance with law. On August 16, 2007, HTPMI executed a
Deed of Assignment in favor of
Philippine Veterans Bank (
petitioner), assigning its rights and interests as seller under the Contract to Sell, including the right to collect payments and to execute acts necessary to enforce compliance. On October 14, 2009, petitioner, through a
Notice of Cancellation by Notarial Act, cancelled or rescinded respondents’ Contract to Sell due to respondents’ default, and demanded that respondents vacate, but they refused. Consequently, petitioner filed an
ejectment/unlawful detainer complaint dated August 20, 2010 before the Municipal Trial Court in Cities of Antipolo City, Branch 1 (
MTCC) docketed as SCA Case No. 093-10. Respondents opposed on the ground that petitioner was not the
real party in interest, insisting that HTPMI retained ownership and that the deed of assignment transferred only receivables rights, not possession or ownership. In its Decision dated April 3, 2013, the MTCC ruled for petitioner, ordered respondents to vacate, and awarded petitioner
P661,919.47 as rent arrears from July 31, 2008 to July 31, 2010,
P10,000.00 as attorney’s fees, and costs. The MTCC held that petitioner, as assignee, was subrogated to HTPMI’s rights under the Contract to Sell and was therefore a real party in interest to enforce the contract. It also found the rental claim just to prevent unjust enrichment. The RTC, in a Decision dated November 28, 2013, affirmed the MTCC, ruling that the deed of assignment gave petitioner not only the right to collect the balance of the purchase price but also the assignor’s rights, including the right to sue in its own name. The CA, in contrast, in its Decision dated October 29, 2015, reversed and set aside the RTC rulings. While the CA initially upheld petitioner’s standing as assignee, it held that because HTPMI retained legal title under the deed of assignment, HTPMI was an
indispensable party who had to be impleaded, and it remanded the case to the MTCC for HTPMI’s inclusion and for trial with dispatch. Upon denial of petitioner’s motion for reconsideration in a Resolution dated April 20, 2016, petitioner sought review before the Court.
Issues:
Whether the CA correctly ruled that
HTPMI is an
indispensable party that must be impleaded in petitioner’s
unlawful detainer suit against respondents.
Ruling:
Ratio:
Doctrine: