GR L 4958; (March, 1954) (Digest)
G.R. No. L-4958 March 30, 1954
MONICO PUENTEVELLA, JR., CARMEN GONZAGA, TEOFILO GENSOLI, LUIS HERVIAS, ANTONIO P. CIOCON, ROSARIO GENSOLIN, MARGARITA TULO, DOLORES TANPINCO, ANGELES JARDELEZA, DOLORES ESTROLOGO, TOMAS JAMILE, and BENJAMIN A. LEDESMA, plaintiffs-appellees, vs. FAR EASTERN AIR TRANSPORT, INC., PHILIPPINE AIR LINES, INC., and COMMERCIAL AIR LINES, INC., defendants, FAR EASTERN AIR TRANSPORT, INC., and PHILIPPINE AIR LINES, INC., defendants-appellants.
FACTS
The plaintiffs are owners of lands adjacent to Bacolod City which the U.S. Army converted into an airfield (Bacolod City Airstrip No. 2) around April 1945. The U.S. Army initially leased the lands from the owners from April 1 to October 15, 1945. After the lease expired, the U.S. Army continued its occupation and later transferred the airstrip to the Surplus Property Commission in April 1947. The Bureau of Aeronautics of the Commonwealth (later Republic) Government maintained and operated the airstrip to promote civil aviation, assuring defendant airlines it would secure leases from the landowners and had funds for rentals. The defendant airlines (FEATI, Philippine Air Lines, and Commercial Air Lines) began using the airstrip between November 1945 and January 1947 under authorization from the U.S. Army and later the Bureau of Aeronautics. The plaintiffs sued the airlines directly to recover the value of the use and occupation of their lands, notwithstanding the government’s role in occupying and operating the airstrip.
ISSUE
Whether the Bureau of Aeronautics is an indispensable party whose absence precludes the court from adjudicating the defendants’ liability for the use of the airstrip.
RULING
Yes. The Supreme Court set aside the lower court’s judgment and remanded the case with instructions to join the Bureau of Aeronautics as an indispensable party defendant. The Court held that the defendants’ liability for using the airstrip is indivisibly linked to the Bureau of Aeronautics’ responsibility. The Bureau occupied, maintained, and operated the airstrip; permitted and encouraged the defendants to use it; and assured them it would handle lease arrangements and payments. Any determination of the defendants’ liability without also determining the corresponding liability of the Bureau of Aeronautics would be inequitable and inconsistent with the complete adjudication of all issues. The Bureau’s interest is so bound up with the controversy that its presence is an absolute necessity for a just and final determination.