Title
Republic vs. Rubin
Case
G.R. No. 213960
Decision Date
Oct 7, 2020
The court denies PRAs motion to intervene in the cancellation of patents for reclaimed lands, citing redundancy with an existing reversion case.
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Case Digest (G.R. No. 213960)

Facts:

  • The Republic of the Philippines, represented by the Philippine Reclamation Authority (PRA), is the petitioner against Ria S. Rubin, the respondent.
  • On February 4, 1977, President Ferdinand E. Marcos issued Presidential Decree No. 1085, transferring ownership and administration of reclaimed lands in Manila Bay to the PRA.
  • On December 8, 1988, the PRA submitted a survey plan to the Department of Environment and Natural Resources (DENR) for a Special Land Patent for reclaimed land identified as Lot Nos. 1 and 2, totaling 45,440 square meters in Las Piñas City.
  • In 1993, the PRA entered into a Memorandum of Agreement with the Manila Electric Company (MERALCO) for the construction of a substation on part of the lots.
  • In 2001, MERALCO informed the PRA that the DENR had lost the original survey plan, leading to a new plan being approved without PRA's clearance.
  • Individuals Espinili Laderas and Edna Laborte filed Miscellaneous Sales Applications for portions of the lots, which were awarded to them by the DENR.
  • In 2007, the DENR canceled the original patents due to overlapping claims and issued new patents with reduced areas.
  • Laderas sold Lot 12 to Ria S. Rubin, who subdivided it, while Laborte sold Lot 13 to her.
  • Rubin filed a complaint against MERALCO for recovery of possession of the lots (Civil Case No. LP-11-0026).
  • The PRA filed a separate complaint for cancellation of the patents and titles (LRC Case No. 12-0057) and sought to intervene in Rubin's case.
  • The Regional Trial Court (RTC) denied the PRA's motion to intervene, stating it lacked authority to preempt another court handling a related case.
  • The PRA's motion for reconsideration was denied, leading to a petition for certiorari with the Court of Appeals, which affirmed the RTC's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petitioner’s omnibus motion to intervene and admit answer-in-intervention was not proper and affirmed...(Unlock)

Ratio:

  • Intervention is a remedy for a third party to protect a right or interest affected by ongoing litigation, but it is not an absolute right and is subject to the court's discretion.
  • The petitioner must show a direct and immediate legal interest in the matter, not a contingent or remote one.
  • The PRA's claim of legal interest based on ownership rights under Presi...continue reading

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