Intervention RULE 19

Intervention (RULE 19) | CIVIL PROCEDURE

Below is an extensive discussion of Intervention under Rule 19 of the Philippine Rules of Civil Procedure, incorporating pertinent legal principles, procedural nuances, and relevant jurisprudence. Although the 2019 Amendments to the Rules of Civil Procedure made certain refinements, the core rules on intervention remain substantially similar. This write-up aims to be as exhaustive as possible while presenting the topic clearly.

I. NATURE AND CONCEPT OF INTERVENTION

  1. Definition
    Intervention is a remedy by which a third person, not originally a party to the suit, seeks to become a party. It is filed by someone who has a legal interest in the matter in litigation, in the success of either of the parties, or against both parties, such that they stand to be affected by a judgment in the action.

  2. Purpose
    The primary purpose of intervention is to enable a person to protect or preserve a right or interest that may be materially affected by the outcome of a pending suit. It prevents multiplicity of suits by allowing parties with a stake in the outcome to participate in ongoing proceedings rather than filing separate actions.

  3. Governing Rule
    Rule 19 of the Rules of Court (Philippines) specifically governs intervention. The current structure and language of Rule 19 derive from the 1997 Rules of Civil Procedure and subsequent amendments, including the 2019 Revised Rules.

  4. Nature of Relief
    Intervention is not a matter of right but is discretionary on the part of the court, subject to specific standards. Courts balance the intervenor’s interest against potential prejudice or delay to the original parties, ensuring that the intervention will aid rather than obstruct the efficient administration of justice.

II. WHO MAY INTERVENE

  1. Persons With a Legal Interest
    Under Rule 19, Section 1, a person who has a legal interest in the matter in litigation, or in the success of either of the parties, or an interest against both parties, or who is so situated as to be adversely affected by a distribution or other disposition of property in the custody of the court, may be permitted by the court to intervene.

  2. Requisites of Legal Interest

    • Direct and Immediate Interest: The interest must be of such direct and immediate character that the intervenor will either gain or lose by the direct legal operation and effect of the judgment.
    • Substantial, Not Merely Contingent: Mere expectancy or a remote or contingent interest is not sufficient.
    • Affected by Final Judgment: The interest must be such that an adverse judgment would affect the rights of the intervenor and cannot be adequately protected in another proceeding.

  3. Entities Eligible to Intervene

    • Natural Persons
    • Juridical Persons (e.g., corporations, partnerships)
    • Government Agencies or Instrumentalities

III. DISTINGUISHING INTERVENTION FROM OTHER PARTY-JOINDER DEVICES

  1. Intervention vs. Necessary and Indispensable Parties

    • Necessary / Indispensable Parties: Must be joined if complete relief cannot be accorded to those already parties, or if the absence of such party would prevent the court from fully determining the controversy.
    • Intervenor: Joins on their own initiative by filing a motion. The court may allow intervention if certain criteria are met. Intervention remains discretionary, whereas joining indispensable parties is mandatory.

  2. Intervention vs. Impleader

    • Impleader (Rule 14): Used by a defending party to bring into the suit a person not a party who is or may be liable for all or part of the plaintiff’s claim.
    • Intervention: A non-party takes affirmative steps to join the suit to protect their rights.

IV. WHEN INTERVENTION MAY BE ALLOWED

  1. Time for Filing
    Intervention may be allowed at any time before rendition of judgment by the trial court, provided it does not unduly delay or prejudice the adjudication of the rights of the original parties.

    • Courts strictly evaluate timeliness. An intervenor must file promptly upon learning of the pending litigation.
    • If a motion for intervention is filed too late (e.g., when the case is already on appeal or after final judgment), it will typically be disallowed.

  2. Discretion of the Court
    The allowance or disallowance of a motion to intervene rests on the sound discretion of the trial court. The following factors are weighed:

    • Timeliness of the application
    • Substantial interest of the intervenor
    • Possible prejudice to the original parties
    • Effect on the orderly conduct of proceedings

  3. Grounds for Denial
    Courts may deny a motion to intervene if:

    • The intervenor’s interest is not direct, immediate, and substantial;
    • The motion is filed out of time and would cause delay;
    • The intervention is only to raise collateral issues or hamper the proceedings;
    • The rights of the intervenor can be adequately pursued in a separate action; or
    • The intervenor has no legal personality or interest in the subject matter of the suit.

V. HOW TO INTERVENE: PROCEDURE

  1. Motion for Intervention

    • Requirement of Motion: To intervene, a would-be intervenor must file a motion for intervention, stating the grounds on which intervention is sought and demonstrating compliance with Rule 19.
    • Timing: As mentioned, it must be filed before the rendition of judgment and without causing undue delay or prejudice.

  2. Pleading in Intervention

    • Attached to the Motion: The motion must be accompanied by a pleading—either a Complaint in Intervention or an Answer in Intervention, depending on whether the intervenor aligns with the plaintiff(s) or the defendant(s).
    • Contents: It must state the intervenor’s interest in the litigation and the causes of action or defenses relevant to that interest.

  3. Opposition to Intervention

    • Any party may file an opposition or comment on the motion for intervention.
    • Arguments typically focus on timeliness, lack of direct interest, or potential prejudice.

  4. Court Resolution

    • Hearing (Discretionary): The court may set the motion for hearing if necessary.
    • Order: The court either grants or denies the motion to intervene. If granted, the attached pleading in intervention is deemed filed.
    • Effect of Grant: The intervenor becomes a party to the case, subject to the same rights and obligations as the original parties.

VI. EFFECTS AND SCOPE OF INTERVENTION

  1. Intervenor’s Rights and Obligations

    • Once allowed, the intervenor has the same procedural rights (e.g., to present evidence, file motions, appeal) as the original parties.
    • The intervenor must take the case as they find it, meaning they cannot re-litigate matters already decided or introduce issues foreign to the suit.

  2. No Delay of Proceedings

    • The original proceedings should not be unduly delayed. The court can impose conditions to mitigate any potential delay, such as limiting discovery.

  3. Binding Effect of Judgment

    • If intervention is granted, the final judgment binds the intervenor, subject to any further appeals the intervenor may file.

VII. REMEDIES IF INTERVENTION IS DENIED

  1. Appeal of Denial

    • Generally, the denial of a motion to intervene is interlocutory and not immediately appealable. The remedy is to raise the denial on appeal from the final judgment if the intervenor believes the denial prevented the full adjudication of substantial rights.

  2. Separate Action

    • The interested person may file a separate action to protect their interest, if doing so is still feasible and not barred by estoppel, prescription, or other defenses.

  3. Extraordinary Remedies

    • In rare instances where denial is patently erroneous or tainted with grave abuse of discretion, the aggrieved party may seek a petition for certiorari (Rule 65) if the court acted in excess or lack of jurisdiction and there is no other plain, speedy, or adequate remedy.

VIII. ILLUSTRATIVE JURISPRUDENCE

  1. Asia’s Emerging Dragon Corporation v. DOTC, G.R. No. 169914 (2006)

    • The Court emphasized that intervention is not a right but a matter of discretion. The applicant must show a clear legal interest in the subject matter of litigation.

  2. Reyes v. COMELEC, G.R. No. 207264 (2013)

    • The Court reiterated that the applicant must prove direct, substantial, and material interest in the case; otherwise, intervention will not be permitted.

  3. First Philippine Holdings Corporation v. Trans Middle East (FPHC Case)

    • The Supreme Court highlighted that an intervenor must accept the pleadings as they stand at the time of intervention; they cannot reshape the existing issues substantially.

IX. LEGAL ETHICS IMPLICATIONS

  1. Duty of Candor

    • A lawyer assisting in intervention must ensure that the motion is filed in good faith, with a clear legal interest. Frivolous or dilatory interventions are unethical.

  2. Avoidance of Delay

    • Counsel must be mindful that the intervention does not serve merely to delay the proceedings. Any misrepresentation or deliberate delay could subject counsel to sanctions.

  3. Conflict of Interest

    • The lawyer must confirm that representing the intervenor does not conflict with the interests of existing clients or parties. The rules on professional responsibility require diligence and fairness to all parties, including the administration of justice.

X. PRACTICAL GUIDELINES AND LEGAL FORMS

  1. Drafting the Motion for Intervention

    • Caption and Title: Identify the court, case number, and title of the case; designate it as a “Motion for Intervention.”
    • Allegations:
      • Nature of the Case (brief statement)
      • Legal Interest of Intervenor (show direct, immediate, and substantial interest)
      • Timeliness (explain why the motion is seasonably filed)
      • Non-Prejudice (explain that granting intervention will not unduly delay the case or prejudice the rights of original parties)

  2. Drafting the Pleading in Intervention

    • Complaint in Intervention or Answer in Intervention:
      • Statement of Material Facts
      • Causes of Action or Defenses
      • Prayer for Relief (what the intervenor wants the court to do)
    • Verification and Certification of Non-Forum Shopping (where required)

  3. Proposed Order

    • Some practitioners attach a proposed order for the court’s convenience, stating the grounds for granting the motion and acknowledging the attached pleading.

XI. SUMMARY OF KEY POINTS

  • Intervention is a discretionary remedy under Rule 19; it allows a third party who has a direct and substantial interest in a pending litigation to join as a party.
  • The motion for intervention must be filed before judgment is rendered by the trial court and must attach the pleading in intervention.
  • Courts consider timeliness, the nature of the intervenor’s interest, and the impact on the existing proceedings in determining whether to grant or deny the motion.
  • An intervenor accepts the case as it is at the time of intervention and is bound by the final judgment once intervention is allowed.
  • Denial of intervention generally may be questioned on appeal from the final judgment, or in extraordinary circumstances, via a petition for certiorari if there is grave abuse of discretion.
  • Parties (and their counsel) must act in good faith and observe ethical standards when seeking to intervene to avoid unnecessary delays or frivolous claims.

Final Note

Intervention ensures that all parties with a legitimate stake in a controversy can be heard and protects their interests in a single proceeding. While courts tend to adopt a liberal approach to intervention to avoid multiplicity of suits and fragmented adjudications, it remains a tool subject to the sound discretion of the trial court. Mastery of Rule 19—particularly understanding the requirements of legal interest, timeliness, and the necessity of an attached pleading—is crucial for any practitioner navigating civil litigation in the Philippines.

Disclaimer: This content is not legal advice and may involve AI assistance. Information may be inaccurate.

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