G.R. No. L-46641: Aranico-Rabino vs. Aquino (Oct 28, 1977) (CASE DIGEST)

Facts

Petitioners, as co-owners, filed a complaint in the lower court seeking to recover possession of a lot from private respondent Victoriano Meimban. Meimban resisted the action, asserting that the property was owned by the late Pedro Meimban and his successors-in-interest, of whom he was one.

During a conference, the trial court determined that to achieve “a final adjudication of the rights of the parties,” the complaint must be amended to include all the heirs of the late Pedro Meimban. Petitioners’ counsel repeatedly refused to comply with this order, arguing that the heirs were not indispensable parties and proposing instead that the trial court “require” the other heirs to file an “answer in intervention”.

The trial court denied the petitioners’ motions and gave them several extended periods, totaling no less than fifty (50) days, to file the required amended complaint. Due to the continued refusal and failure to comply, the respondent Judge ordered the case DISMISSED without prejudice.

Issues

1. Did the Supreme Court err in upholding the dismissal of the petitioners’ complaint based on the plaintiff’s failure to comply with the trial court’s order to include all indispensable parties?
2. Was the trial court correct in ruling that the heirs of the deceased Pedro Meimban were indispensable parties whose inclusion was mandatory for a final adjudication?

Ruling

“WHEREFORE, the petition is DENIED due course for obvious lack of merit.”

Essential Elements of Jurisprudence

The controlling doctrines and legal principles established by the Supreme Court are:

1. Authority to Dismiss for Non-Compliance: The trial court is expressly empowered to dismiss an action, either upon the motion of the defendant or upon the Court’s own motion, if the plaintiff fails to comply with these rules or any order of the court. (Citing Section 2, Rule 17 of the Revised Rules of Court).
2. Indispensable Parties: Persons (such as co-owners or heirs of a deceased property owner) who are necessary for a complete and final adjudication of the rights of the parties in a case must be included as parties. (Citing Rule 3, Section 7 of the Revised Rules of Court).
3. Voluntary Nature of Intervention: The procedure of intervention is strictly a purely voluntary act on the part of a person who has legal interest in the litigation. (Citing Section 2, Rule 12 of the Revised Rules of Court). Requiring an indispensable party to intervene is therefore unprocedural.
4. Justification for Dismissal: A plaintiff’s failure and refusal to comply with a court order requiring the amendment of a complaint to include indispensable parties, even after being granted multiple extensions, is sufficient legal ground for the dismissal of the case.

Sample Q&A

Question: A plaintiff (P) files suit to recover land. The defendant successfully argues that P failed to include all known co-owners, who are necessary for a final judgment on ownership. The court orders P to amend the complaint to include these co-owners. P refuses, claiming the co-owners can simply “intervene,” and is subsequently given a total of 50 days to comply before the court dismisses the action without prejudice. Did the trial court commit reversible error by dismissing the case?Answer: No. The trial court acted within its lawful authority. The heirs/co-owners are indispensable parties whose inclusion is required by the Revised Rules of Court (Rule 3, Section 7) to ensure a final adjudication of the rights of all parties. Furthermore, the court has the express power to dismiss an action if the plaintiff fails to comply with any court order (Revised Rules of Court, Rule 17, Section 2). Finally, P’s suggestion that the court force the co-owners to intervene is legally unsound, as intervention is a purely voluntary act (Revised Rules of Court, Rule 12, Section 2). The repeated refusal to comply with a proper order, despite extended time, justified the dismissal.

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