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PHILIPPINE NATIONAL BANK v. HEIRS OF ESTANISLAO MILITAR

This case has been cited 6 times or more.

	GR No. 177598 2008-10-16	ROBERT SAN PEDRO v. WILLY ONG CHICO-NAZARIO, J.
The Court defined indispensable party in Philippine National Bank v. Heirs of Estanislao Militar and Deogracias Militar, [33] as follows:An indispensable party is one whose interest will be affected by the court's action in the litigation, and without whom no final determination of the case can be had. The party's interest in the subject matter of the suit and in the relief sought are so inextricably intertwined with the other parties' (sic) that his legal presence as a party to the proceeding is an absolute necessity. In his absence there cannot be a resolution of the dispute of the parties before the court which is effective, complete, or equitable.
	GR No. 151016 2008-08-06	SPS. SOFRONIO SANTOS AND NATIVIDAD SANTOS v. HEIRS OF DOMINGA LUSTRE NACHURA, J.
On the issue of prescription and laches, we fully agree with the CA. The action for reconveyance on the ground that the certificate of title was obtained by means of a fictitious deed of sale is virtually an action for the declaration of its nullity, which does not prescribe.[37] Moreover, a person acquiring property through fraud becomes, by operation of law, a trustee of an implied trust for the benefit of the real owner of the property. An action for reconveyance based on an implied trust prescribes in ten years. And in such case, the prescriptive period applies only if there is an actual need to reconvey the property as when the plaintiff is not in possession of the property. Otherwise, if plaintiff is in possession of the property, prescription does not commence to run against him. Thus, when an action for reconveyance is nonetheless filed, it would be in the nature of a suit for quieting of title, an action that is imprescriptible.[38]
	GR NO. 135817 2006-11-30	REYNALDO RODRIGUEZ v. CONCORDIA ONG LIM CALLEJO, SR., J.
Conversely, a party is not indispensable to the suit if his interest in the controversy or subject matter is distinct and divisible from the interest of the other parties and will not necessarily be prejudiced by a judgment which does complete justice to the parties in court. He is not indispensable if his presence would merely permit complete relief between him and those already parties to the action or will simply avoid multiple litigation.[24]
	GR NO. 157434 2006-09-19	SPS. CLARO AND NIDA BAUTISTA v. BERLINDA F. SILVA AUSTRIA-MARTINEZ, J.
To prove good faith, a buyer of registered and titled land need only show that he relied on the face of the title to the property. He need not prove that he made further inquiry for he is not obliged to explore beyond the four corners of the title.[37] Such degree of proof of good faith, however, is sufficient only when the following conditions concur: first, the seller is the registered owner of the land; [38] second, the latter is in possession thereof;[39] and third, at the time of the sale, the buyer was not aware of any claim or interest of some other person in the property,[40] or of any defect or restriction in the title of the seller or in his capacity to convey title to the property.[41]
	GR NO. 160994 2006-07-27	WILFREDO v. PAULO FLORESCA CALLEJO, SR., J.
Conversely, a party is not indispensable to the suit if his interest in the controversy or subject matter is distinct and divisible from the interest of the other parties and will not necessarily be prejudiced by a judgment which does complete justice to the parties in court. He is not indispensable if his presence would merely permit complete relief between him and those already parties to the action or will simply avoid multiple litigation.[26] With respect to Civil Case No. 832-BG, Paulo was an indispensable party thereto as well as the siblings Victor, Juanito, and Lilia as it involved the subject property which they acquired from their ascendants, the deceased parents of Paulo and Alberto. It was, in fact, a partition of the estate of their ascendants. Paulo and, in representation of their father Alberto, Victor, Juanito, and Lilia, as the heirs, may be properly considered indispensable parties thereto. Indeed, a final determination could be had therein even without the petitioners as their claim of interest was merely derived from Paulo's interest. In other words, they merely stepped into his shoes as his successors-in-interest.
	GR NO. 160843 2006-07-11	CHINA BANKING CORPORATION v. MARIA G. LAGON QUISUMBING, J.
Moreover, petitioner could not be considered a mortgagee in good faith. It had knowledge that respondent was in the United States at the time the SPAs were allegedly executed, yet, it did not question their due execution. Though petitioner is not expected to conduct an exhaustive investigation on the history of the mortgagor's title, it cannot be excused from the duty of exercising the due diligence required of a banking institution.[14] Banks are expected to exercise more care and prudence than private individuals in their dealings, even those that involve registered lands, for their business is affected with public interest.[15]