G.R. No. L-30526 November 29, 1971
BATAMA FARMER’S COOPERATIVE MARKETING ASSOCIATION INC. and IGNACIO VICENTE, petitioners, vs. HONORABLE INOCENCIO ROSAL, in his capacity as Judge of the Court of First Instance of Negros Oriental, ANTONIO VILLEGAS and JUAN TEVES, respondents.

FACTS

Respondent Antonio Villegas filed a complaint for injunction and damages against petitioner Batama Farmer’s Cooperative Marketing Association, Inc. He alleged that having resigned as a member and revoked his “Marketing Agreement and Power of Attorney,” the cooperative should be enjoined from managing and marketing his sugar cane for the 1968-1969 crop year. Petitioners filed their Answer, denying the material averments and asserting affirmative defenses.
Subsequently, respondent Juan Teves filed an urgent motion for intervention, attaching a proposed complaint-in-intervention. He claimed a legal interest and a common cause of action with Villegas, asserting that he, too, was a member who had executed a similar marketing agreement with the same cooperative and that the cooperative lacked authority to act under such agreements. Petitioners opposed the motion, arguing that Teves’s agreement was entirely distinct and separate from Villegas’s, and that any rights or grievances arising therefrom could not be joined in one action. The respondent judge granted the motion for intervention, finding that Teves had a legal interest in the matter in litigation. Petitioners’ motion for reconsideration was denied.

ISSUE

Whether or not the respondent judge committed grave abuse of discretion in allowing the intervention of respondent Juan Teves.

RULING

Yes, the Supreme Court granted the petition and set aside the orders allowing intervention. The legal logic is anchored on the strict requirements for permissible intervention under Section 2, Rule 12 of the Rules of Court. To intervene, a party must have a legal interest in the matter in litigation, which must be actual, material, direct, and immediate, not merely contingent or expectant. The Court held that Teves’s interest failed this test.
The cause of action of Villegas arose from his specific contract and his act of resignation and revocation. Teves’s rights and obligations stemmed from a separate and distinct contract with the cooperative. While the contracts were similar in form, a breach of one does not automatically constitute a breach of the other. Their enforcement could not be joined in one complaint, as each planter’s case would depend on the particular facts and defenses applicable to his individual agreement. Allowing intervention based merely on a similarity of contracts would lead to the absurdity that anytime one member filed a suit, all other members with similar contracts could intervene, causing unnecessary complexity and delay. Teves’s proper remedy was to institute a separate action, which could potentially be consolidated for joint hearing if found feasible. Therefore, the respondent judge gravely abused his discretion in permitting the intervention.