Case Summary (G.R. No. 211149)
Factual Background
The case originated from a forcible entry suit filed by Alfredo Sering against respondents Restituto Plazo and Gertrudes Suan in the Municipal Court of del Carmen, Surigao del Norte. The Municipal Court ruled in favor of Sering, prompting the Plazos to appeal to the Court of First Instance of Surigao del Norte. During the appellate process, the Plazos discovered that the property in question was co-owned by Sering and others, which led them to assert that all co-owners should be joined in the suit as indispensable parties.
Legal Dispute
The Plazos moved to require Sering to include the other co-owners in his complaint, asserting that this was necessary based on the principle of indispensable parties. However, Sering opposed this, claiming that under Article 487 of the Civil Code, a single co-owner could bring an ejectment action without the necessity of joining any other co-owners. The Trial Court sided with the Plazos, ordered Sering to amend his complaint to include the co-owners, and ultimately dismissed his complaint when he failed to comply.
Trial Court's Decision
The Trial Court dismissed Sering's complaint based on his non-compliance with the order for amendment, leading to his eventual motion for reconsideration being denied. Sering then sought to overturn these orders from the Supreme Court, arguing that the dismissal was erroneous.
Supreme Court Analysis
The Supreme Court began its analysis by reaffirming the principles established in previous rulings, particularly referencing the case of Vencilao v. Camarenta. The Court reiterated that under Article 487 of the Civil Code, any individual co-owner is permitted to bring an action for ejectment without the necessity of including the other co-owners. The Court highlighted that ejectment actions focus primarily on the question of prior physical possession rather than ownership nuances, reinforcing the notion that a single party with possession can initiate such legal procee
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Case Overview
- This case concerns an ejectment action initiated by Alfredo Sering against Restituto Plazo and Gertrudes Suan, resulting in an appeal due to procedural disputes regarding co-ownership of the property in question.
- The case was adjudicated by the Supreme Court of the Philippines, under G.R. No. L-49731, on September 29, 1988.
Legal Context
- Article 487 of the Civil Code is pivotal, allowing any co-owner of an immovable property to file an action for ejectment without the necessity of joining other co-owners.
- The terms "forcible entry" (detentacion) and "unlawful detainer" (desahucio) are included under the umbrella of ejectment actions.
Procedural History
- The case began as a forcible entry suit filed by Sering in the Municipal Court of del Carmen, Surigao del Norte.
- Following a judgment against the Plazos, they appealed to the Court of First Instance of Surigao del Norte, where they discovered that the property wa