Case Summary (G.R. No. 138497)
Petitioner
Imelda Relucio, alleged cohabitant of Alberto J. Lopez since 1976 and owner, jointly or severally, of properties at issue.
Respondent
Angelina Mejia Lopez, legally married to Alberto J. Lopez, plaintiff in Special Proceedings No. M-3630 for appointment as administratrix of conjugal partnership, accounting, support, forfeiture and dissolution of marital property.
Other Parties
Regional Trial Court of Makati, Branch 141 (trial court)
Court of Appeals, Fifth Division (CA)
Key Dates
• September 15, 1993 – Filing of Special Proceedings No. M-3630.
• December 8, 1993 – Petitioner’s Motion to Dismiss.
• February 10 and May 31, 1994 – Trial court orders denying motion to dismiss and reconsideration.
• June 21, 1994 – Petition for certiorari filed with the CA.
• May 31, 1996 – CA decision denying certiorari.
• April 6, 1999 – CA denial of motion for reconsideration.
• January 16, 2002 – Supreme Court decision.
Applicable Law
• 1987 Philippine Constitution
• Rule 45, Revised Rules of Court (Certiorari)
• Rules 3, Sections 2, 7, 8, Revised Rules of Court (Joinder of Parties)
• Family Code, Article 128 (Administration of Conjugal Partnership)
Factual Background
Angelina filed for appointment as sole administratrix of her conjugal partnership with Alberto, accounting, support, forfeiture of Alberto’s share in property co-owned with Imelda, and dissolution of the conjugal partnership. She alleged Alberto abandoned the family in 1968, controlled and dissipated conjugal assets, then cohabited with Imelda since 1976 and acquired substantial properties in their names or through dummies.
Procedural History
Imelda moved to dismiss for lack of cause of action, which the trial court denied, ruling her a necessary party since some properties were registered in her name. After a denied motion for reconsideration, Imelda filed a petition for certiorari in the CA; the CA denied relief and denied reconsideration. Imelda then elevated the case to the Supreme Court under Rule 45.
Issues Presented
- Whether Angelina’s petition for administratrix appointment, accounting, support, forfeiture and dissolution of conjugal partnership establishes a cause of action against Imelda.
- Whether Imelda’s inclusion as defendant is essential or indispensable for a complete adjudication of the controversy.
Supreme Court’s Analysis on Cause of Action
• A cause of action requires (1) a right in favor of the plaintiff, (2) a corresponding duty on the defendant, and (3) an act or omission breaching that duty.
• Angelina’s claims arise exclusively from her marital rights against Alberto: administration of marital property (Family Code Art. 128), accounting of conjugal partnership, support, forfeiture of Alberto’s share in co-owned property with Imelda, and dissolution of the conjugal partnership.
• Imelda, as a non-spouse and third party, owes no legal duty to Angelina under the Family Code or general law. References to Imelda in the petition serve only to establish factual context for Alberto’s alleged misconduct.
• No element of a cause of action exists against Imelda. She cannot be held liable for marital obligations or for enforcement of forfeiture against Alberto.
Supreme Court’s Analysis on Joinder of Parties
• A real party in interest must stand to be benefited or injured by the judgment.
Case Syllabus (G.R. No. 138497)
Procedural Posture
- Petition for review on certiorari under Rule 45 seeking to set aside the Court of Appeals’ decision in CA-G.R. SP No. 34398 promulgated May 31, 1996, which denied petitioner’s certiorari petition.
- Original special proceeding (Spec. Proc. M-3630) filed September 15, 1993, in the Regional Trial Court of Makati, Branch 141.
- Trial court denied petitioner’s Motion to Dismiss (Order February 10, 1994) and subsequent Motion for Reconsideration (Order May 31, 1994).
- Court of Appeals denied certiorari petition (May 31, 1996) and motion for reconsideration (April 6, 1999).
- Petition for review on certiorari filed June 18, 1999; due course given September 15, 1999.
Facts
- In 1968, Alberto Lopez allegedly abandoned his wife Angelina Mejia Lopez and their four legitimate children.
- From 1976, Alberto Lopez cohabited with Imelda Relucio, petitioner, in an illicit relationship.
- During cohabitation, Lopez and Relucio amassed properties—corporate stockholdings, real estate, vehicles, bank accounts, jewelry—registered in their names or through proxies.
- Lopez purportedly used conjugal assets exclusively for himself and Relucio, excluding his lawful wife and children.
- Lopez allegedly concealed, transferred, sold, or otherwise disposed of conjugal partnership properties to evade support obligations.
- Angelina Lopez filed a petition for appointment as sole administratrix of conjugal partnership, forfeiture, dissolution of conjugal gains, accounting, support, and moral damages aga