G.R. No. L-5458
BONIFACIO POBRE, ET AL., plaintiffs-appellees, vs. ISMAEL BLANCO, defendant-appellant.
October 5, 1910

FACTS:
On July 13, 1908, Bonifacio Pobre initiated an action in the Court of First Instance of Ilocos Norte against Ismael Blanco to recover possession of three parcels of land and their produce. The defendant, Ismael Blanco, filed an answer claiming ownership of the land along with other individuals.

On January 5, 1909, Bonifacio Pobre filed an amended complaint, adding Tomasa Blanco, Engracia Blanco, and Teresa Blanco as plaintiffs, and including additional parcels of land. The plaintiffs claimed the land by virtue of inheritance from Victor Blanco and Agustina Abrenica, who were husband and wife. Victor and Agustina had four daughters: Tomasa, Engracia, Irene, and Teresa. Irene was married to Bonifacio Pobre, and they had three children: Isidro, Pedro, and Prudencia. Irene died before the commencement of the action. Bonifacio Pobre, as a plaintiff, represented his three minor children. However, the record did not show any court appointment authorizing him as guardian of their estate.

The defendant’s amended answer indicated that several other individuals, including Antero de los Reyes, Alaide Duque, Estanislao Duque, Miguel Duque, Juana Quebral, Victor Blanco, Doroteo Blanco, Leoncio Blanco, Bernardino Sadumiano, Ismael Blanco, and another Victor Blanco, were interested parties and claimed ownership of portions of the land in question. These individuals were not made parties to the action.

The lower court ruled in favor of the plaintiffs, declaring them the owners of the land. The defendant appealed after his motion for a new trial was denied.

ISSUE:
1. Whether Bonifacio Pobre had the authority to represent his minor children in the litigation without a court appointment as guardian of their estate.
2. Whether all persons interested in the land in question must be made parties to the action for a proper adjudication of rights.

RULING:
The Supreme Court reversed the decision of the lower court.

1. The Court held that Bonifacio Pobre was without authority to represent his minor children (Isidro, Pedro, and Prudencia) in the litigation, as there was no showing that he had been appointed by the court as guardian of their estate, as required by Section 553 of the Code of Procedure in Civil Actions.
2. The Court further ruled that when it appeared on record that there were other persons interested in the land who were not parties to the action, it was the duty of the lower court to suspend the trial until all such persons were made parties, either as plaintiffs or defendants. Section 114 of the Code of Procedure in Civil Actions mandates that all persons having an interest in the subject of the action and in obtaining the relief demanded shall be joined as parties.

Due to these procedural deficiencies, the Court found it impossible to determine who was rightfully entitled to the land. The judgment of the lower court was therefore reversed, and the record was ordered returned to the lower court with directions that, if the parties desired to continue the litigation, all interested persons in the land must be made parties, either as plaintiffs or defendants. No findings as to costs were made.