### Facts:
This case involves a property dispute over a 463-square meter land in Pangasinan, initially titled under Flaviana De Gracia, who died intestate in 1980. Her heirs, Hilaria Martin-Paguyo and Elena Martin-Alvarado, waived their hereditary rights to the land in favor of Francisca Medrano in 1982, in recognition of expenses Medrano incurred for De Gracia’s medical and burial costs. Medrano took possession and, after the refusal of other heirs to renounce their rights, initiated a case for quieting of title and reconveyance against several defendants in 2001. During the litigation, respondent Estanislao D. De Vera acquired rights to the property from some defendants and intervened in the case. The trial court admitted De Vera’s participation but later reversed its decision, proceeding with an ex parte presentation of evidence against the defaulting original defendants and not recognizing De Vera’s interest. The Regional Trial Court’s decision favored Medrano, which De Vera challenged through a Petition for Certiorari and Mandamus at the Court of Appeals (CA), arguing the trial court’s error in proceeding ex parte despite his rightful interest in the case.
### Issues:
1. Whether De Vera could participate in Civil Case No. U-7316 without filing a motion to intervene.
2. Whether De Vera is bound by the judgment against his transferors.
3. Whether the CA properly took cognizance of respondent’s Petition for Certiorari and Mandamus.
### Court’s Decision:
The Supreme Court affirmed the CA’s decision, holding that the trial court gravely abused its discretion by not allowing De Vera to participate in the trial. The decision noted that De Vera’s interest, being a transferee pendente lite, was inextricably linked to the original defendants and thus he should have been allowed to participate without filing a motion to intervene. The Court also clarified that a transferee pendente lite is bound by judgment against the transferor but highlighted the importance of observing due process rights, which were violated in disallowing De Vera’s participation. Furthermore, the CA’s acceptance of the Petition for Certiorari and Mandamus was deemed appropriate given the circumstances, marking the trial court’s decision as one done in grave abuse of discretion.
### Doctrine:
1. A transferee pendente lite is bound by judgments rendered against the transferor.
2. Failure to observe due process by disallowing a party’s participation in a case constitutes a grave abuse of discretion.
3. Certiorari under Rule 65 is an appropriate remedy when a lower court’s proceedings are conducted in such a way that deprives an interested party of their right to participate, and when no other speedy and adequate remedy exists.
### Class Notes:
– **Transferee Pendente Lite**: A person who acquires interest in a property under litigation during the pendency of the case. Such a transferee is considered joined in the action from the moment of transfer and bound by the judgment as if they were an original party.
– **Due Process**: The constitutional guarantee that all parties must have the opportunity to be heard and to participate in proceedings. Violating a party’s right to due process, such as by denying participation in trial, constitutes grave abuse of discretion.
– **Certiorari under Rule 65**: A special civil action against a tribunal, board, or officer exercising judicial functions, employed to correct acts executed with grave abuse of discretion resulting in lack or excess of jurisdiction when there is no appeal or any plain, speedy, and adequate remedy.
### Historical Background:
This case highlights significant issues about property rights, the interpretation of legal standing, and procedural concerns in Philippine law, particularly in how the judiciary handles cases involving interests acquired during litigation. It reinforces the courts’ roles in ensuring fair process and adjudication, shaping jurisprudence on property disputes and the principles surrounding due process rights and the appropriate use of judicial remedies.
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