G.R. Nos. 99338-40 February 1, 1993
HEIRS OF NICOLAS Y. OROSA (Represented herein by their Attorney-in-Fact, RICARDO Q. OROSA), petitioners, vs. THE HON. EUTROPIO MIGRINO, Presiding Judge, Regional Trial Court of Pasig, M.M. Branch 151 and GOLDENROD, INC., respondents.

FACTS

In a prior case (G.R. No. L-30859), the Supreme Court affirmed a decision confirming ownership of a 53-hectare parcel of land (Lot 9 Psu-11411 Amd-2) in favor of Dominador Mayuga and extended the benefit of such confirmation to his successor-in-interest, the late Nicolas Orosa. After remand to the Regional Trial Court (RTC) of Pasig (Land Registration Case No. 2839), the heirs of Nicolas Orosa moved for execution of judgment. The RTC granted the motion and directed the Land Registration Authority to submit the property’s amended technical description. However, the LRA did not comply, noting its records indicated the property had previously been decreed in favor of one Jose T. Velasquez (OCT No. 6122). Goldenrod, Inc. then filed a motion for leave to intervene in the execution proceeding, alleging an interest in the property. The petitioners opposed, but the RTC permitted the intervention. The petitioners’ motion for reconsideration was denied, prompting this Petition for Certiorari and Prohibition.

ISSUE

1. Whether Goldenrod, Inc. has shown in its pleadings in intervention a sufficient legal interest in the land which is the subject matter of LRC No. 2839.
2. Whether the legal interest actually shown by Goldenrod over the land can be protected in a proceeding separate from LRC No. 2839.

RULING

1. No. Goldenrod failed to show a sufficient legal interest to justify intervention. Goldenrod claimed that in 1977, Delta Motors Corporation acquired the contingent rights of Nicolas Orosa and the conflicting claims of Jose Velasquez. Delta later obtained transfer certificates of title and sold the property to Goldenrod in 1987. Goldenrod then obtained Transfer Certificates of Title Nos. 4893 and 4901, which overlapped portions of Lot 9. In February 1989, Goldenrod sold the land to a consortium, with an undertaking to defend the title against third-party claims. The Court found that whatever direct and actual legal interest Goldenrod may have had was disposed of in 1989. Any residual interest based on its contractual warranty against eviction was merely expectant or contingent. A party seeking to intervene must have an actual and material, direct and immediate legal interest, meaning they will gain or lose by the direct legal effect of the judgment. Goldenrod did not meet this criteria. The RTC gravely abused its discretion in permitting intervention after overlooking this matter. The RTC’s invocation of Section 32 of P.D. 1529 (permitting reopening of a decree within one year for fraud) was bereft of basis, as Goldenrod had not shown any actual interest of which it was deprived due to fraud.
2. Yes. Given the remote and contingent nature of Goldenrod’s legal interest, it can and should protect such interest in a separate proceeding. The RTC, upon entry of the Supreme Court’s judgment in G.R. No. L-30859, was divested of general jurisdiction over LRC No. 2839, save for the limited matter of supervising the execution process. It could not interpret or reverse the implication of the Supreme Court’s ruling confirming petitioners’ title just because Goldenrod made a supervening allegation. Goldenrod’s reliance on the Suson v. Court of Appeals case was misplaced, as the intervenor there had a direct and actual legal interest. The considerations of due process and substantial justice present in Suson did not obtain here. The RTC’s action caused needless complication, expense, and delay in the execution proceedings to the prejudice of petitioners’ right to a speedy disposition. Goldenrod’s contingent interest, arising from its warranty, can be litigated in a separate action, such as an action for quieting of title.