Thus, to the extent that Defendants base their argument on the heirs' status as beneficiaries, the heirs of the land grant cannot be necessary and indispensable to this litigation involving land. {20} Even assuming that the land grant is a trust and the heirs the beneficiaries, the heirs would not be necessary parties because this Court rejected the earlier rule found in the annotation, and has held that beneficiaries of a trust are not generally necessary parties. Armendaris Water Dev. Co. v. Rainwater, 109 N.M. 71, 74, 781 P.2d 799, 802 (Ct.App. 1989). In Armendaris, this Court adopted the proposition that "the trustee may represent the beneficiary as in all actions relating to the trust, if rights of the beneficiary against the trustee, or the rights of the beneficiaries among themselves, are not brought into question."

The Mallon lien attached to the one-half interest in the property. Armendaris Water Development Co. v. Rainwater, 109 N.M. 71, 75, 781 P.2d 799, 803 (Ct.App. 1989) (Liens only attach to a debtor's beneficial interest in a property). See also McCord, 67 N.M. at 66, 352 P.2d at 644 (Judgment liens do not attach to property for which debtor has bare legal title.)

We, however, need not resolve this matter because, even assuming the Garcias were successors in interest to the State, the other premise of their argument-that the State was a necessary and indispensable party to the foreclosure action-fails. For their contention that the district court lacked jurisdiction to enter the judgment and order, the Garcias rely on Armendaris Water Development Co. v. Rainwater, 1989-NMCA-077, 109 N.M. 71, 781 P.2d 799. Armendaris held that a trial court is without jurisdiction to enter a judgment ordering foreclosure where a person whose rights were affected by the judgment, i.e., an "indispensable party," is absent from the proceedings. See id. ¶ 8.