- Petitioner
- Nieves Plasabas
- Respondent
- Court of Appeals (Special Former Ninth Division)
- Citation
- G.R. No. 166519
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Nachura, J.
- Decided
- March 31, 2009
Summary
Property dispute over coconut land inherited from common ancestor Francisco Plasabas. Petitioners sued for recovery of title and possession but trial court dismissed case for failure to implead co-owner siblings as indispensable parties after protracted 19-year trial. Court of Appeals affirmed dismissal. Supreme Court reversed, holding under Article 487 of Civil Code that co-owners may bring actions for recovery of possession without joining other co-owners, as such suits benefit all co-owners. Court emphasized non-joinder of indispensable parties warrants impleading, not dismissal. Case remanded to trial court for merit determination, establishing important precedent on co-ownership litigation and procedural requirements.
Intellegal Wiki · Key Holding
Any one co-owner may bring an action to recover the co-owned property for the benefit of all (Article 487) without joining the other co-owners; non-joinder is not a ground for dismissal.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.