Aron v.

Realon
January 31, 2005, | G.R. No. 159156

RAMON P. ARON, petitioner, vs. FRANCISCO REALON,

DOMINGO REALON and FELIPE REALON, representing the
HEIRS OF MARCIANO REALON and ROMAN REALON,
EMILIANO R. PURIFICACION, representing the HEIRS OF
ALFREDO REALON and ROMAN REALON, respondents.

G.R. No. 159156 January 31, 2005 Callejo, Sr., J.

Summary
Ramon Realon was the owner of wo parcels of land which was inherited by Alfredo
Realon and the heirs of Buenaventura. Sometime in 1979, Alfredo and the heirs executed
a contract of sale on the lots they inherited in favor of Ramon Aron. Alfredo obliged
himself to execute the deed of sale upon the register of sale or upon the full payment of
the purchase, but Alfredo failed to register the sale; therefore, Aron refused to pay the
remaining balance. Aron registered the sale himself and mortgaged the property to the
remaining heir. Alfredo and Marciano died intestate, and their heirs were not aware of
the sale of the land. Engr. Ilaban, representing Aron, filed a case of consignation against
the heir of Realon. The RTC rendered a decision in favor of Realon; therefore, the heirs
filed a reconveyance before the RTC Cavite Branch. The Realon contends that the undue
influence was present at the execution of the sale and that the balance of the price due in
the contract was not paid. Aron contended that the contract to sell was superseded by
the deeds of sale with mortaged, but the Realons answered and said that they did not
receive any proceeds from the contract. The Regional Trial Court of Cavite Branch
rendered a decision in favor of the Realons, which was affirmed as well by the Court of
Appeals when Aron filed for an appeal.
Doctrines and Relevant Concepts
 Rule 3 of the Rules of Court reads:

SEC. 7. Compulsory joinder of indispensable parties. — Parties in interest without whom

no final determination can be had of an action shall be joined either as plaintiffs or
defendants.

 Indispensable Parties- Failure to include the other indispensable parties in a

complaint is fatal to the case as the court will not be able to exercise its judicial
power over the case.
Facts
 Ramon Realon was the owner of two parcels of land which was inherited by his
son Alfredo Realon and the heirs of his deceased son, Buenaventura, namely,
Marciano, Joaquino, Florentino, Felipe, Marcelo, Sesinando, and Montano. One of
 the lots, which is Lot. 1253 was divided between the heirs of Ramon-- Alfredo and
the sons of Buenaventura. Both Alfredo and the sons of Bunavetura sold their
portion of their lot to Ramon Aron. Two contracts of sale were executed, one from
Alfredo and the other from the heirs of Buenaventura, under Marciano as the
attorney-in-fact. The deed of sale will be provided only once the full payment from
Aron or once the OCT will be secured. Alfredo promised to secure the OCT of his
divided lot to Aron, but failed to do so; therefore, Aron refused to pay the balance
of the sale of land.
 Given the failure of Alfredo to file a petition to register the property, Aron filed it
himself. Aron was able to receive the Deed of Sale with mortgage in order to
secure the remaining balance of the purchase price. The application was final and
executory.
 In 1989 and in 1990, Alfredo and Marciano died intestate respectively, and their
heirs were unaware of the sale of the lot. Engr. Ilaban, the attorney-in-fact of Aron,
filed a case for consignation against the heirs of the deceased Alfredo and
Marciano. The Heirs countered by contending that undue influence was present at
the execution of the sale and that the balance of the price due in the contract to
sell was not paid, which is around P129,349.73. Aron contended that the contract
to sell was superseded by the deeds of the sale with mortgage, and that all of his
balance were paid including the P42,849.23, which he deposited with the Clerk of
Court of the RTC. The Heirs contended that even the other heirs did not receive
any proceeds from the contract and that their predecessors did not sell the
property to Aron.
 The RTC rendered a decision that the consignation was valid and released Aron
from his obligations under the Deed of Sale with Mortgage. The said decision was
final and executory as the Heirs did not appeal or moved for a reconsideration.
The Heirs, as representatives of the signatories of the contract, instead filed a
reconveyance complaint against Aron before the RTC of Bacoor, Cavite. Aron filed
an answer stating that the respondents are not authorized to sue in a
representative capacity, there being no testate nor intestate proceedings for the
estate of the deceased whom they represent.
 The RTC Bacoor, Cavite branch rendered a decision that Aron falsely alleged in his
application of the lot that he was the owner of the property based on a deed of
sale, when in fact under the contracts to sell executed by Alfredo and Marciano, he
would acquire title over the property only upon payment of the full purchase
price and on the execution of the FINAL deed of sale. In addition, it held that the
property is still under the possession of the heirs of Alfredo and Marciano, which
they continued to pay realty taxes therein under the name of Roman Realon.
 Aron filed an appeal before the Court of Appeals but was also dismissed. The
appellate court agreed in toto with the decision of the RTC Bacoor, Cavite Branch.
Hence, a petition before the Supreme Court.
Issues
W/N the signatories of the contract of sale, the other heirs of Alfredo, Marciano, and
Marcelo are the indispensable parties of the case.
Held/Ruling
The Supreme Court found merit on the petition of Ramon Aron. Under Section 7 of Rule 3
of the Rules of Court, it is stated that parties in interest without whom no final
determination can be had of an action shall be joined either as plaintiffs or defendants. In
other words, the Court held that the presence of all indispensable parties is a condition of
sine qua non (necessary) for the exercise of the court’s judicial power. The plaintiff is
mandated to implead all indispensable parties, absence of one renders all subsequent
actions of the court null and void for want of authority to act, not only as to the absent
parties, but even as to those present. In the case at bar, all the surviving signatories of the
contract of sale, namely, Joaquino, Francisco, Felipe, Sesinando, and Monatno, and other
surviving heirs of Alfredo, Marciano, and Marcelo were indispensable parties. The
defendants only impleaded on this case were Francisco, Domingo, Felipe, and Emiliano
Purificacion. The surviving signatories of the assailed deeds and the other heirs were not
included as impleaded parties; therefore, the trial court and the Court of Appeals erred in
rendering a decision on the present case.
DISPOSITION
IN LIGHT OF ALL THE FOREGOING, the petition is GRANTED. The assailed decision of the
Court of Appeals in CA-G.R. CV No. 68979, and that of the Regional Trial Court, are SET
ASIDE. No costs.