GR 107762; (August, 1995) (Digest)
G.R. No. 107762, August 29, 1995
Alberto S. Acenas II, petitioner, vs. Court of Appeals, Hon. Antonio P. Solano, in his capacity as Presiding Judge of the Regional Trial Court of Quezon City, Branch 86, Rodrigo S. Ligon and Deputy Sheriff Edgardo D. Tanangco, respondents.
FACTS
Private respondent Rodrigo S. Ligon filed a complaint for sum of money and damages with a prayer for a writ of attachment against Evelyn L. Guanzon (also known as Evelyn Acenas). The complaint alleged Guanzon issued dishonored checks for purchased jewelry and had absconded abroad. Ligon specifically sought to attach Guanzon’s alleged one-half interest in a property covered by TCT No. 44209, registered in the name of “ALBERTO S. ACENAS, JR., married to EVELYN LALIC.” Summons was served via substituted service. Petitioner Alberto S. Acenas II, claiming to be the Alberto Acenas in the title, filed a motion for leave to intervene, asserting exclusive ownership over the property and denying any marriage to Guanzon that would give her a conjugal interest.
The trial court denied Acenas’s motion for intervention, granted Ligon’s prayer for attachment, and later rendered a default judgment against Guanzon. Acenas filed a third-party claim, which was also denied. The Court of Appeals subsequently dismissed Acenas’s petition to stop the execution, prompting this appeal.
ISSUE
Whether the trial court gravely abused its discretion in denying petitioner Acenas’s motion for leave to intervene in the civil case.
RULING
Yes. The Supreme Court granted the petition and ordered that Acenas be allowed to intervene. Under Section 2, Rule 12 of the Rules of Court, intervention is permitted if a person has a legal interest in the matter in litigation or in the property in custody of the court. The Court emphasized a liberal approach, especially when sought early in the proceedings to avoid multiplicity of suits.
The core legal logic is that the trial court’s jurisdiction over the case against the absent defendant, Evelyn Guanzon, was quasi in rem, anchored on its jurisdiction over the res—the attached property. Since Acenas claims exclusive ownership of that very same res, his legal interest is direct and substantial. Allowing his intervention was essential to determine the validity of the court’s exercise of jurisdiction and to settle the antagonistic claims to the property in a single proceeding, thereby achieving a complete and economical resolution. While the Court noted Acenas’s questionable denial of marriage to Guanzon, the greater interest of justice in preventing multiple litigations over the same property warranted permitting the intervention.