G.R. No. 138497 ; January 16, 2002
Imelda Relucio, petitioner, vs. Angelina Mejia Lopez, respondent.

FACTS

Angelina Mejia Lopez, the lawful wife of Alberto Lopez, filed a petition in the Regional Trial Court for appointment as sole administratrix of the conjugal partnership properties, accounting, and forfeiture of Alberto’s share in properties acquired with his alleged paramour, Imelda Relucio. The petition alleged that Alberto abandoned his family in 1968 and later cohabited with Relucio starting 1976. It claimed that Alberto used conjugal funds to acquire properties, many of which were registered in Relucio’s name alone or jointly with Alberto, to the exclusion of his lawful family. The petition sought relief primarily against Alberto Lopez.
Imelda Relucio filed a Motion to Dismiss the case against her, arguing that the petition stated no cause of action against her, a stranger to the marriage. The trial court denied the motion, ruling she was a necessary or indispensable party because some contested properties were registered in her name. The Court of Appeals affirmed this denial. Relucio thus elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

The primary issue is whether the petition filed by Angelina Mejia Lopez states a valid cause of action against Imelda Relucio, thereby warranting her inclusion as a party defendant in the suit for administration of conjugal property and related reliefs.

RULING

The Supreme Court granted the petition and dismissed the case against Imelda Relucio. The Court held that the complaint failed to state a cause of action against Relucio. A cause of action requires a legal right of the plaintiff, a correlative obligation of the defendant, and an act or omission by the defendant violating that right. The allegations in the petition sought relief exclusively against the husband, Alberto Lopez, for judicial appointment as administratrix, accounting, support, and dissolution of the conjugal partnership under Article 128 of the Family Code. These causes of action pertain solely to the spouses. Relucio, not being a spouse, had no legal obligation to Angelina regarding the administration of the latter’s conjugal property.
Furthermore, the Court ruled Relucio was not an indispensable party. An indispensable party is one without whom no final determination of the action can be had. A judgment could perfectly be rendered ordering Alberto Lopez to account for conjugal properties, provide support, and forfeit his share in properties co-owned with Relucio, all without Relucio’s participation. She was also not a necessary party, as complete relief could be accorded to Angelina through a judgment solely against her husband. The claims against properties registered in Relucio’s name involved issues of co-ownership or implied trust between her and Alberto, which were separate from the intra-spousal causes of action and could be litigated in a different proceeding.