GR 169276; (June, 2009) (Digest)
G.R. No. 169276 June 16, 2009
DIONISIA MONIS LAGUNILLA and RAFAEL MONIS, Petitioners, vs. ANDREA MONIS VELASCO and MACARIA MONIS, Respondents.
FACTS
Rev. Fr. Patricio Monis and Magdalena Catalina Monis, siblings of respondents Andrea Monis Velasco and Macaria Monis, acquired several properties, including a parcel of land in Quezon City co-owned with Andrea and Pedro Velasco. Petitioners Dionisia Monis Lagunilla and Rafael Monis are the children of Venancio Monis, another sibling of the deceased. After the deaths of Patricio and Magdalena, respondents executed a Deed of Extrajudicial Settlement with Donation over the Quezon City property, donating it to Andrea’s son, Pedro Monis Velasco, Jr., and securing a new title in his name. Petitioners filed an action for Annulment of Documents and Damages, alleging respondents fraudulently misrepresented themselves as the only surviving heirs, excluding petitioners who claim a right to represent their deceased father Venancio. The Regional Trial Court (RTC) dismissed the complaint and awarded damages to respondents. The Court of Appeals affirmed with modification, deleting exemplary damages and attorney’s fees. Petitioners elevated the case to the Supreme Court.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in its rulings, particularly regarding the validity of the extrajudicial settlement, the finding of absence of fraud or bad faith, the award of moral damages, and the denial of petitioners’ motion to amend the complaint to implead an indispensable party.
RULING
The Supreme Court granted the petition. The Court found that Pedro Monis Velasco, Jr., the donee of the property subject of the Deed of Extrajudicial Settlement with Donation, is an indispensable party to the action for annulment. Without his inclusion, no final determination of the case can be had, as any judgment would directly affect his interests under the assailed deed and the title issued in his name. The lower courts’ failure to order his joinder was a fatal defect. Consequently, the Supreme Court set aside the decisions of the Court of Appeals and the RTC and remanded the case to the RTC for the joinder of Pedro Monis Velasco, Jr. as an indispensable party and for further proceedings. The Court did not rule on the substantive issues raised by petitioners due to this jurisdictional prerequisite.