4/7/2021
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or violation thereof. The purpose of the action is to secure an
authoritative statement of the rights and obligations of the parties
under a statute, deed, contract, etc. for their guidance in its
enforcement or compliance and not to settle issues arising from its
alleged breach. It may be entertained only before the breach or violation
of the statute, deed, contract, etc. to which it refers. Where the law or
contract has already been contravened prior to the filing of an action for
declaratory relief, the court can no longer assume jurisdiction over the
action. In other words, a court has no more jurisdiction over an action for
declaratory relief if its subject, i.e., the statute, deed, contract, etc., has
already been infringed or transgressed before the institution of the action.
Under such circumstances, inasmuch as a cause of action has already
accrued in favor of one or the other party, there is nothing more for the
court to explain or clarify short of a judgment or final order. (Emphasis
supplied)
Thus, it is required that the parties to the action for declaratory relief be those whose
rights or interests are affected by the contract or statute being questioned.[39] Section
2 of Rule 63 of the Rules of Court further underscores that a judgment in a petition for
declaratory relief binds only the impleaded parties:
Section 2. Parties. — All persons who have or claim any interest which would
be affected by the declaration shall be made parties; and no declaration
shall, except as otherwise provided in these Rules, prejudice the rights of
persons not parties to the action. (2a, R64)
Heirs of Marcelino Doronio v. Heirs of Fortunato Doronio[40] further elucidates on
this principle, thus:
Petitioners cannot also use the finality of the RTC decision in
Petition Case No. U-920 as a shield against the verification of the
validity of the deed of donation. According to petitioners, the said
final decision is one for quieting of title. In other words, it is a case
for declaratory relief under Rule 64 (now Rule 63) of the Rules of
Court, which provides:
SECTION 1. Who may file petition. - Any person interested under
a deed, will, contract or other written instrument, or whose rights
are affected by a statute, executive order or regulation, or
ordinance, may, before breach or violation thereof, bring an
action to determine any question of construction or validity
arising under the instrument or statute and for a declaration of
his rights or duties thereunder.
An action for the reformation of an instrument, to quiet title to real property
or remove clouds therefrom, or to consolidate ownership under Article 1607
of the Civil Code, may be brought under this rule.
SECTION 2. Parties. - All persons shall be made parties who have
or claim any interest which would be affected by the declaration;
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