G.R. No. 183059 - Quilatan vs. Heirs of Quilatan

On August 15, 1999, petitioners Ely Quilatan and Rosvida Quilatan-Elias filed a complaint for nullification of Tax Declaration Nos. D-014-00330 and D-014-00204 and for partition of the estate of the late Pedro Quilatan, including a claim for damages, against the respondent heirs of Lorenzo Quilatan.
The petitioners alleged that Pedro Quilatan owned two parcels of land in Taguig, Metro Manila covered by Tax Declarations Nos. 1680 and 2301. In 1998, they discovered these tax declarations were cancelled without their knowledge and replaced with new ones under the names of Spouses Lorenzo Quilatan and Anita Lizertiquez.

On June 22, 2004, the RTC declared the cancellation of Tax Declaration Nos. 1680 and 2301 void.
The court ordered the partition of the subject properties into three equal shares among the heirs of Pedro Quilatan’s children: Francisco, Ciriaco, and Lorenzo.

The CA reversed the RTC decision and dismissed Civil Case No. 67367 without prejudice on the ground that petitioners failed to implead all indispensable parties—specifically the other heirs of Pedro Quilatan who are necessary for a valid partition suit.
Petitioners moved for reconsideration, which was denied.

Petitioners argued that the failure to implead indispensable parties was a new issue raised only in the respondents’ Motion for Reconsideration, not in their Answer to the complaint.
They claimed that dismissal without prejudice and mandatory re-filing would cause multiplicity of suits, as the partition had been correctly ordered.

Pedro Quilatan died intestate in 1960, survived by three children: Ciriaco, Francisco, and Lorenzo—all deceased at the time of the case.
The heirs of Ciriaco were Purita Santos, Rosita Reyes, Renato Quilatan, Danilo Quilatan, and Carlito Quilatan.
The heirs of Francisco were petitioners Ely Quilatan, Rosvida Quilatan-Elias, Solita Trapsi, and Rolando Quilatan.
Lorenzo was survived by the respondent heirs.
The petitioners failed to implead Solita, Rolando, and the heirs of Ciriaco in the complaint.

Whether the dismissal of Civil Case No. 67367 without prejudice by the Court of Appeals for failing to implead indispensable parties was proper.
Whether the failure to implead all heirs affects the jurisdiction and validity of the trial court’s decision.
Whether dismissal without prejudice and re-filing of the case will cause multiplicity of suits unjustly.
The identification and role of indispensable parties in an action for partition of co-owned properties.