G.R. No. 225752 . March 27, 2019.
SEVERINO A. YU, RAMON A. YU, AND LORENZO A. YU, PETITIONERS, VS. DAVID MIRANDA, MORNING STAR HOMES CHRISTIAN ASSOCIATION – SAN JOSE BIÑAN – HOMEOWNERS ASSOCIATION, INC., TIMMY RICHARD T. GABRIEL, AND LILIBETH GABRIEL, RESPONDENTS.

FACTS

Respondent David Miranda filed a sum of money case against respondent Morning Star Homes Christian Association, Inc. and others before the RTC. The RTC granted Miranda’s prayer for a writ of preliminary attachment over properties registered under Morning Star’s name. Petitioners Severino, Ramon, and Lorenzo Yu later moved to intervene, claiming they were the real owners of the attached properties. They alleged Morning Star was merely a nominal owner, holding title only to facilitate a loan, and that the deed of sale in its favor was void for lack of consideration.
The RTC denied the Motion for Leave to Intervene, ruling the petitioners were not the registered owners and could protect their rights in a separate proceeding. Subsequently, the RTC rendered a final and executory decision in the main money case in favor of Miranda. The petitioners then filed a Petition for Certiorari before the CA, challenging the denial of their intervention.

ISSUE

Whether the Court of Appeals correctly dismissed the Petition for Certiorari assailing the denial of the Motion for Leave to Intervene.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA’s dismissal, primarily on the ground of mootness. The core legal logic is that a petition for certiorari seeking to reverse an order denying intervention becomes moot and academic once a final and executory judgment has been rendered in the main case. At that point, allowing intervention would serve no practical purpose, as the trial court would have lost jurisdiction to modify its final judgment. The petitioners’ objective in intervening—to protect their alleged interest in the attached properties from being levied to satisfy the judgment—could no longer be achieved through intervention in the concluded case.
The Court further clarified that the denial of a motion to intervene is not a denial of due process. Intervention is not a matter of right but rests on judicial discretion. More importantly, the petitioners were not without an adequate remedy. The Court noted they had already filed a separate civil action (Civil Case No. B-9126) against Morning Star for annulment of deed of sale, reconveyance, and damages—a direct action precisely aimed at establishing their ownership over the same properties. The pendency of this separate action provided them a plain, speedy, and adequate remedy at law. A successful outcome in that case would mean the properties never rightfully belonged to the judgment debtor, Morning Star, and thus could not be subject to a valid levy for Miranda’s claim. Therefore, the special civil action of certiorari was improper, and no grave abuse of discretion attended the RTC’s order.