G.R. No. L-5458 - Pobre vs. Blanco

On July 13, 1908, Bonifacio Pobre commenced an action in the Court of First Instance of the Province of Ilocos Norte against Ismael Blanco.
The action was aimed at recovering the possession of three parcels of land along with its produce until the case's resolution.

The defendant, Ismael Blanco, filed both a general and a special answer. In his special answer, he asserted that he, along with others, was the rightful owner of the land.
On January 5, 1909, the plaintiff filed an amended complaint incorporating Tomasa Blanco, Engracia Blanco, and Teresa Blanco as additional plaintiffs.
The amended complaint also expanded the subject matter by including more parcels of land not previously delineated in the original complaint.

The plaintiffs claimed the land through inheritance from Victor Blanco and Agustina Abrenica, a husband-and-wife couple who had died some years prior to the case's commencement.
During the marriage of Victor Blanco and Agustina Abrenica, four daughters were born: Tomasa, Engracia, Irene, and Teresa.
Irene, one of the daughters, had married Bonifacio Pobre, through whom he asserted his claim by representing his progeny — Isidro, Pedro, and Prudencia — from their marriage.
It was established that Irene had died before the onset of the litigation; however, the record did not provide the specific date of her death.

Bonifacio Pobre represented his three minor children in the suit.
The record lacked evidence of any court appointment authorizing him as guardian of the estate or conferring authority to represent the minors, contrary to the requirement under Sec. 553, Code of Procedure in Civil Actions.
During the trial, Pobre acknowledged that his intervention was on behalf of his children.

The defendant’s amended answer introduced additional interested parties, including Antero de los Reyes, Alaide Duque, Estanislao Duque, Miguel Duque, Juana Quebral, Victor Blanco, Doroteo Blanco, Leoncio Blanco, Bernardino Sadumiano, Ismael Blanco, and another Victor Blanco, all of whom were asserted to have an interest in a portion of the land.
The presence of other interested parties not joined in the litigation raised the issue of proper joinder, as all persons with an interest in the subject of the action are required, by law, to be either plaintiffs or defendants (Sec. 114, Code of Procedure in Civil Actions).

After the evidence was presented, the lower court rendered a decision in favor of the plaintiffs and against the defendant, declaring that the plaintiffs were the rightful owners of the contested land.
A motion for a new trial was subsequently filed by the defendant, was denied, and an exception was raised against the ruling, leading to the present appeal.

Whether Bonifacio Pobre had the proper authority to represent his minor children in the litigation, given the absence of a court-appointed guardianship order or other legal authorization.

Whether the lower court erred in proceeding with the trial despite the existence of multiple other interested parties, whose rights in the land were not adequately represented or joined in the action.
The issue includes the application of procedural requirements under Sec. 114 of the Code of Procedure in Civil Actions regarding the joinder of all persons having an interest in the subject matter of the litigation.

Whether, in light of the unjoined interested parties and incomplete representation, it was possible to definitively determine and declare the rightful owner of the land.