GR 165987; (March, 2006) (Digest)
G.R. No. 165987 ; March 31, 2006
JOSHUA S. ALFELOR and MARIA KATRINA S. ALFELOR, Petitioners, vs. JOSEFINA M. HALASAN, and THE COURT OF APPEALS, Respondents.
FACTS
The heirs of the late spouses Telesforo and Cecilia Alfelor filed a Complaint for Partition before the RTC of Davao City. Among the plaintiffs were Teresita Sorongon and her children, petitioners Joshua and Maria Katrina Alfelor, claiming to be the surviving spouse and legitimate children of Jose Alfelor, a son of the deceased. Respondent Josefina Halasan filed a Motion for Intervention with an attached Answer, asserting she was the lawful surviving spouse of Jose, having married him in 1956. She contended that Jose’s subsequent marriage to Teresita was void and that the petitioners were not Jose’s legitimate children. She prayed, among other things, for the appointment of a special administrator.
The RTC denied Josefina’s motion and dismissed her complaint-in-intervention. The trial court ruled she failed to substantiate her claim, as she did not appear to testify or present a witness to properly identify and authenticate the presented marriage contract. It found Teresita’s testimony credible, noting her good faith belief in the validity of her marriage to Jose, as Josefina had been absent for many years. The RTC thus declared Teresita and the petitioners as the legal heirs of Jose. The Court of Appeals reversed the RTC, ordering the admission of Josefina’s complaint-in-intervention.
ISSUE
Whether the Court of Appeals erred in reversing the RTC and ordering the admission of respondent Josefina Halasan’s complaint-in-intervention.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. The legal logic centers on the permissive nature of intervention under Rule 19 of the Rules of Court and the proper stage for determining the merits of an intervenor’s claim. An intervention is allowed when the intervenor has a legal interest in the matter in litigation, or in the success of either party, or an interest against both, provided it will not unduly delay or prejudice the adjudication of the original parties’ rights.
Josefina clearly possessed a direct legal interest, claiming to be the lawful surviving spouse and compulsory heir of Jose Alfelor, whose estate share was the subject of the partition suit. Her claim directly affected the determination of legitimate heirs and the distribution of the estate. The RTC erred in dismissing the intervention based on a preliminary assessment of the evidence’s sufficiency, which prematurely adjudicated the merits of her claim. The validity of her marriage and the legitimacy of the petitioners are ultimate issues that require a full-blown trial for proper determination, not summary resolution at the intervention stage. The purpose of intervention is to settle all related controversies in a single proceeding to avoid multiplicity of suits. Thus, Josefina should be allowed to intervene, and the trial court must conduct a full trial to resolve the factual and legal issues she raised.