G.R. No. L-29591 - Piramide vs. Go Guioc Sian

On April 19, 1968, Napoleon N. Piramide filed a complaint in the Court of First Instance of Southern Leyte, Maasin Branch.
The complaint involved a dispute over two parcels of coconut land allegedly connected with the partition of Narciso Piramide’s estate.

Plaintiff-Appellant: Napoleon N. Piramide, who claimed that he represented his deceased father, Fermin, and contended to be one of Narciso Piramide’s legal heirs.
Defendants-Appellants: Go Guioc Sian (an alien and widow of the late Chinaman Valentin Tan) and Benjamin K. Piramide (Napoleon’s cousin).
Other heirs: The complaint mentioned two additional heirs, Pedro Piramide and Pilar Piramide-Revill, though their relationship and participation were not clearly delineated in the original pleadings.

A 19-hectare land located at Sitio Buenavista, Burgos, Malitbog, Leyte.
An 8-hectare land located at Sitio Cantotang, Burgos, Malitbog.
Allegedly, the rights over these properties were derived from contracts among the parties concerning a debt of P7,746.90 owed by the late Narciso Piramide to Valentin Tan.

Acknowledged the debt and secured payment using the two parcels of land.
Involved Pedro Piramide, Pilar Piramide, and Go Guioc Sian, wherein the 19-hectare land was conveyed to Sian, while the 8-hectare land was to be received by Pedro and Pilar on a conditional payment plan.

The second notarized contract (June 3, 1948), known as “Kaligunan sa Gikasabutan”:

Executed by Pilar, Pedro, Go Guioc Sian, and Benjamin K. Piramide.
Allegedly transferred the 19-hectare land exclusively to Go Guioc Sian and the 8-hectare land to Benjamin K. Piramide.
Notably, the contract was in the Cebuano dialect, with no translation provided as required by Rule 132, Section 34 of the Rules of Court.

Napoleon contended that the two contracts are void due to the defect of being in pari delicto with Go Guioc Sian, and that his opponents forfeited their interests by being equally at fault.
He claimed that by these void contracts, he became the sole owner of the contested properties and also prayed for payment corresponding to the value of the copra extracted from these lands.
Despite his later assertions in briefs, his original complaint did not categorically state his interest in the properties nor did it mention that the properties formed part of Narciso Piramide’s estate.

Defendants moved to dismiss the complaint based on prescription, lack of a cause of action, and the nonjoinder of essential parties (Pedro Piramide and Pilar Piramide-Revill).
The trial court noted that Napoleon failed to clearly allege any direct interest or a specific right which was infringed, and observed that the involvement of other heirs was indispensable in a case involving partition and property rights.
Consequently, the trial court required the amendment of the complaint to include Pedro and Pilar as necessary parties and to more clearly allege Napoleon’s interest, failing which the complaint would be dismissed.
Napoleon opted against amending his complaint, leading to its dismissal on July 20, 1968.

Whether the complaint sufficiently stated a cause of action by properly alleging Napoleon N. Piramide’s interest and the legal basis for invalidating the contracts.
Whether the vague and inconsistent allegations (such as not specifying the exact share in the contested properties or the relationship to Narciso’s estate) rendered the cause of action uncertain.

Whether the failure to join Pedro Piramide and Pilar Piramide-Revill as defendants (or co-parties) was an error, given that they were indispensable for a complete adjudication of the dispute over the partitions.
Whether the trial court’s requirement to implead these additional parties was proper under the rules governing necessary parties.

Whether the contracts executed with Go Guioc Sian, and involving Pedro, Pilar, and Benjamin, should be declared void due to alleged defects, including the lack of a proper translation and the relationship among the contracting parties.
Whether, under the doctrine of pari delicto, all contracting parties should have been joined to establish the complete context of the voiding claim.