Case Summary (G.R. No. 204222)
Facts of the Case
The case stems from an incident on August 10, 2010, when Rolando Flores and Jhannery Hupa were apprehended while transporting a trailer truck containing a container van, which was suspected to house copper wires owned by Meralco. The police confiscated the truck's contents after seizing the materials and charging the accused with theft under Section 3 of Republic Act No. 7832. Neptune, which claimed ownership of the scrap copper wires, sought court permission to inspect the seized property, asserting its legal interest in the contents of the container. The Regional Trial Court (RTC) initially allowed inspection and eventually ordered the quashal of the information due to the lack of evidence confirming that the stolen items belonged to Meralco.
Court of Appeals Resolutions
Meralco filed a petition for certiorari before the CA without including Neptune in the process. Subsequently, Neptune filed a motion for leave to intervene, asserting its rights to the scrap copper wires. The CA denied Neptune's intervention on grounds that it had demonstrated no legal interest in the case and had filed the motion late. The CA's reasoning included the lack of legal connection between the scrap copper wires claimed by Neptune and the wires originally alleged to be stolen from Meralco, and the perception that Neptune's involvement in the RTC proceedings was not sufficient to support its claim.
Parties' Arguments
Neptune contended that it had considerable legal interest stemming from its ownership of the scrap copper wires and highlighted the potential loss of its property if the original charges were reinstated. It claimed that its persistent assertion of ownership and involvement in RTC proceedings established its right to intervene. Conversely, the Office of the Solicitor General (OSG), representing the People of the Philippines, argued that Neptune's motion raised factual questions inappropriate for a Rule 45 petition and emphasized that Neptune had no legal interest in the case, asserting that the actual ownership question was irrelevant as the container van had not been submitted as evidence.
Court's Ruling
The Supreme Court granted Neptune’s petition, concluding that the CA erred in denying the motion to intervene. The Court held that intervention is permissible for parties with a legitimate interest in a case, particularly when an intervenor’s rights may be negatively affected by the proceedings. It determined
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Case Overview
- The case involves a petition for review on certiorari filed by Neptune Metal Scrap Recycling, Inc. (Neptune) challenging the resolutions of the Court of Appeals (CA) that denied Neptune's motion for leave to intervene and to admit a comment-in-intervention in a criminal case against Rolando Flores and Jhannery Hupa.
- The CA's resolutions were dated March 20, 2012, and October 19, 2012.
Factual Background
- Neptune's involvement began with a criminal case filed against Flores and Hupa for allegedly stealing electric power transmission scrap copper wires owned by the Manila Electric Company (Meralco).
- On August 10, 2010, authorities detained the accused, who were transporting a trailer truck loaded with a container van suspected to contain stolen materials.
- The police seized the truck and its contents, leading to charges under Section 3 of Republic Act No. 7832.
- Neptune claimed ownership of the thirteen bundles of scrap copper wires worth about P8,000,000, presenting several documents to support its assertion.
- The Regional Trial Court (RTC) allowed Neptune to inspect and later ordered the return of the container van and the three remaining bundles of copper wires after determining that no Meralco property was found in the van.