Misjoinder of causes of action not ground for dismissal - G.R. No. 153829

G.R. No. 153829 (click link)

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Next, the RCA submits that an action for quieting of title is a special civil action covered by Rule 63, while an action for declaration of nullity of title is governed by ordinary rules. Thus, it contends that these cases should have been dismissed for violation of the rule on joinder of actions under Section 5, Rule 2 of the 1997 Rules of Civil Procedure, as amended, which requires that the joinder shall not include special civil actions governed by special rules. Such contention, however, is utterly bereft of merit and insufficient to show that the CA erred in upholding the trial court’s decision. Section 6 of Rule 2 explicitly provides that misjoinder of causes of action is not a ground for dismissal of an action.

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