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Republic vs. Rubin

The Supreme Court denied the Philippine Reclamation Authority's (PRA) motion to intervene in a case regarding reclaimed lands, affirming that intervention is not a matter of right and would be redundant due to a separate reversion case already filed by PRA. The case involves a dispute over ownership of lots along the Manila Cavite Coastal Road, with PRA claiming ownership while Ria S. Rubin sought possession from the Manila Electric Company. The Court concluded that allowing PRA to intervene could lead to conflicting decisions and that its rights were already protected in the pending reversion case.

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77 views2 pages

Republic vs. Rubin

The Supreme Court denied the Philippine Reclamation Authority's (PRA) motion to intervene in a case regarding reclaimed lands, affirming that intervention is not a matter of right and would be redundant due to a separate reversion case already filed by PRA. The case involves a dispute over ownership of lots along the Manila Cavite Coastal Road, with PRA claiming ownership while Ria S. Rubin sought possession from the Manila Electric Company. The Court concluded that allowing PRA to intervene could lead to conflicting decisions and that its rights were already protected in the pending reversion case.

Uploaded by

gabriel.manalastas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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9/5/24, 12:27 PM Republic vs.

Rubin

Title
Republic vs. Rubin

Case Decision Date


G.R. No. 213960 Oct 7, 2020

The court denies the Philippine Reclamation Authority's motion to intervene in a case
involving the cancellation of patents and titles for reclaimed lands, ruling that
intervention is not a matter of right and would be redundant due to a separate reversion
case already filed by the authority.

Case Digest (G.R. No. 213960)


Comprehensive

Facts:
The case "Republic of the Philippines v. Rubin" (G.R. No. 213960) involves a dispute over
reclaimed lands located along the Manila Cavite Coastal Road in Las Piñas City. The
petitioner, the Republic of the Philippines represented by the Philippine Reclamation
Authority (PRA), sought to intervene in a case where respondent Ria S. Rubin filed an
accion reinvindicatoria against the Manila Electric Company (MERALCO) to recover
possession of the disputed lots. The case stems from a series of events beginning with
Presidential Decree No. 1085 issued by President Ferdinand E. Marcos on February 4, 1977,
which transferred ownership and administration of reclaimed lands in Manila Bay to the
Public Estates Authority (now PRA). PRA submitted a survey plan to the Department of
Environment and Natural Resources-National Capital Region (DENR-NCR) in 1988 to
secure a Special Land Patent for the reclaimed land. However, the DENR-NCR lost the
survey plan, and another plan was approved without PRA's clearance. This led to the
issuance of Miscellaneous Sales Patents to Espinili Laderas and Edna Laborte, who later
sold the lots to Rubin. Rubin then filed a complaint against MERALCO, while PRA filed a
separate reversion case to cancel the patents and titles. PRA's motion to intervene in
Rubin's case was denied by the Regional Trial Court (RTC) Branch 255, and this denial was
affirmed by the Court of Appeals.

Issue:
1. Is the petitioner's omnibus motion to intervene and admit answer-in-intervention in
Civil Case No. LP-11-0026 proper?

Ruling:
The Supreme Court denied the petition and affirmed the Court of Appeals' decision, which
upheld the RTC's denial of PRA's motion to intervene.

https://jur.ph/jurisprudence/v/digest/republic-v-rubin?q=G.R.+No.+213960+-++Republic+vs.+Rubin 1/2
9/5/24, 12:27 PM Republic vs. Rubin

Ratio:
The Supreme Court held that intervention is not a matter of right but is subject to the
court's discretion. Under Rule 19 of the Rules of Court, intervention requires a legal interest
in the matter in litigation and consideration of whether the intervention will unduly delay
or prejudice the adjudication of the original parties' rights. The Court found that PRA had a
legal interest in the subject matter, as it claimed ownership and possession of the disputed
lots. However, PRA's rights were already being protected in a separate reversion case
pending before another branch of the RTC (Branch 198), which had already ruled in PRA's
favor. The Court noted that allowing PRA to intervene in Rubin's case would be redundant
and could lead to conflicting decisions. The RTC Branch 255 had also suspended its
proceedings pending the finality of the reversion case, recognizing that the resolution of
the reversion case would effectively settle the dispute. Therefore, the Court concluded that
the denial of PRA's motion to intervene was proper.

https://jur.ph/jurisprudence/v/digest/republic-v-rubin?q=G.R.+No.+213960+-++Republic+vs.+Rubin 2/2

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