KUPALOURD Rule 19 Intervention

REM 1 BRONDIAL

Rule 19 Intervention

Anonuevo v Intestate Estate of Jalandoni

Who is Anonuevo here? What kind of a party was he? He was the intervenor. Under Rule 19 on
intervention, what are the requirements? Must have legal interest in the matter in litigation, or interest
in the success of the plaintiff, or interest in the success of the defendant. The kind of pleading you are
bound to file depends on whose interest you are with if you are with the plaintiff, you file a complaint
in intervention; if you are with the defendant, you file an answer in intervention; if neither, you file a
complaint in intervention.

Going back to the facts, Anonuevo and siblings filed an intervention in the intestate proceedings. What
was their claim? They claim that they have a share in the intestate estate because their grandmother
was married to the deceased. What was their evidence? Birth certificate. The administrator of the
estate contends that such was not sufficient because the evidence necessary is a marriage contract, and
they were able to establish that their grandmother was married to somebody else. The issue is do the
intervenors have interest in this case? The trial court said yes. But on appeal with the CA, it reversed
the RTC. The SC ruled that they do not have interest, as they were not able to establish that they were
grandchildren to Jalandoni, the deceased.

What was the doctrine in Yao v Perello? When can one intervene in a case, at what point in time you
can only intervene before the rendition of judgment. After rendition of judgment, there is no more
right to intervene. Exception: Pinlac v CA: intervenor was the government, in the interest of
substantial justice (intervention was already when case was on motion for reconsideration with the
Supreme Court)

Rule 20, 21, 22 = READ!

Take note of how to quash a subpoena and viatory (not sure about this) right under Sec. 10, Rule 21.
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