G.R. No. 106194 August 7, 1997
SANTIAGO LAND DEVELOPMENT CORPORATION, petitioner, vs. THE HONORABLE COURT OF APPEALS and the HEIRS OF NORBERTO J. QUISUMBING, respondents.

FACTS

This case involves a motion for reconsideration filed by petitioner Santiago Land Development Corporation. Petitioner purchased a parcel of land from the Philippine National Bank (PNB) while a case for its recovery, filed by Norberto J. Quisumbing against PNB (Civil Case No. 10513), was pending. Petitioner sought to intervene in that case under Rule 12, §2 of the Rules of Court. The Supreme Court, in its original decision, denied this right to intervene. In its motion for reconsideration, petitioner argues that foreign jurisprudence, cited in legal commentaries, supports the intervention of a purchaser pendente lite. It also contends that denying intervention violates equal protection and corrects a factual error in the original decision regarding whether PNB raised a defense under Article 1491(5) of the Civil Code.

ISSUE

Whether the petitioner, as a voluntary purchaser pendente lite, has a legal right to intervene in the pending action between its vendor (PNB) and the original plaintiff (Quisumbing).

RULING

The Supreme Court denied the motion for reconsideration. The Court clarified that the foreign jurisprudence cited by petitioner, primarily from Moore’s Federal Practice, is inapplicable. The cited cases involved purchasers at execution or sheriff’s sales, not voluntary sales. In such involuntary sales, the buyer acquires the property adverse to the owner’s interest and cannot rely on the owner to defend its title, thus creating a reasonable necessity for intervention to protect the buyer’s distinct interest. In contrast, petitioner is a voluntary vendee of PNB. As a transferee pendente lite, it is bound by the judgment in the case under Rule 3, §20 and stands in the shoes of its vendor. The Court found that PNB, as the original defendant, is actively presenting “formidable” defenses, which petitioner itself acknowledges. Therefore, there is no “reasonable necessity” for petitioner’s intervention, as its interest is already being adequately protected by PNB. The constitutional claim of denial of equal protection fails because petitioner is not deprived of a hearing; its rights are fully represented by its predecessor-in-interest. The Court acknowledged the factual error regarding the Article 1491(5) defense but held this correction did not warrant a modification of the decision, as it did not affect the core legal reasoning on intervention.