G.R. No. L-3928 July 27, 1951
REPUBLIC OF THE PHILIPPINES, petitioner, vs. BONIFACIO YSIP, Judge of the Court of First Instance of Bulacan and BALDOMERO SILVERIO, as administrator of the Intestate of Gregorio Silverio, respondents.

FACTS

During the Japanese occupation, the Taiwan Tekkosho, a Japanese corporation, constructed two storehouses (bodegas) on land belonging to the intestate estate of Gregorio Silverio in Plaridel, Bulacan. After Liberation, the Philippine Alien Property Administrator, acting under the Trading with the Enemy Act and related laws, issued Vesting Order No. P-159, divesting the enemy corporation of all title to the bodegas and transferring them to the United States Government, subject to valid claims. Baldomero Silverio, as administrator of the estate, filed a civil case (No. 415) in the Court of First Instance of Bulacan against the Philippine Alien Property Administration and the Municipality of Plaridel, seeking recovery of the land, a declaration that the bodegas are estate property (allegedly given by the Japanese before leaving), and damages. The Republic of the Philippines, through the Chief Special Attorney of the Department of Justice, moved to intervene in the case. The trial court, presided by Judge Bonifacio Ysip, denied the motion, ruling that the Republic’s interest was merely contingent and expectant. A motion for reconsideration was also denied. The Republic then filed this petition for certiorari and mandamus. The Philippine Alien Property Administrator was allowed to intervene as amicus curiae.

ISSUE

Whether the Republic of the Philippines has a sufficient legal interest to warrant its intervention in Civil Case No. 415 under Rule 13, Section 1 of the Rules of Court.

RULING

Yes. The Supreme Court granted the petition, set aside the orders of the trial court, and ordered that the Republic be allowed to intervene. The Court held that under Section 3 of the Philippine Property Act of 1946, vested properties located in the Philippines, after satisfaction of claims and administrative costs, are to be transferred to the Republic of the Philippines. This establishes in the Republic a substantial, real, and eventual interest in the property, giving it a “legal interest in the matter in litigation” or “in the success of either of the parties” as required by Rule 13, Section 1. The fact that this interest is contingent upon the outcome of claims and litigation does not make it merely expectant for purposes of intervention. Furthermore, the Republic, through its agencies, possesses distinct advantages and facilities for inquiring into the nature and history of vested properties and can assist the court and the Philippine Alien Property Administrator in resisting improper claims. The Court also noted that the Philippine Alien Property Administrator did not object to, and in fact welcomed, the Republic’s intervention. The intervention would not delay or prejudice the adjudication of the original parties’ rights but would aid the trial court in its determination. The trial court therefore committed a grave abuse of discretion in denying the motion to intervene.