ORQUIOLA VS. CA
TOPIC: RULE 3 - Section 9. Non-joinder
of necessary parties to be pleaded
Facts: Ledesma was the registered owner of Lot 689.
This parcel of land was adjacent to certain portions of Lot 707 of the
Piedad Estates, registered in the name of Pedro. Pedro sold Lot 707-A and 707-B
to Lising who then registered both lots and Lot 707-C in the name of M.B.
Lising Realty and subdivided them into smaller lots. Certain portions of the
subdivided lots were sold to third persons including Orquiola (1964).
Sometime in 1969, Ledesma filed a complaint in RTC against Pedro and Lising
for allegedly encroaching upon Lot
689. During the pendency of the action, Tandang
Sora Development Corporation replaced Ledesma as plaintiff by virtue of an
assignment of Lot 689 made by Ledesma in favor of said corporation.
In 1991, RTC finally adjudged defendants Pedro and Lising jointly and
severally liable for encroaching on plaintiff’s land.
Issue: WON the decision in the Civil Case can be
enforced against petitioners even though they were not impleaded thereto
Held:
NO, petitioners are not privies (interested in
the outcome of the action) and cannot be bound by the judgment against
Lising and his predecessors-in-interests.
The Medina doctrine relied upon by the CA is markedly different from the
one before the court. In the present case, petitioners acquired the lot before
the commencement of Civil Case and petitioners acquired the registered title in
their own names.
In other words, the sale to petitioners was made before Ledesma claimed
the lot. Petitioners could reasonably rely on Lising’s Certificate of Title
which at the time of purchase was still free from any third-party claim.
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