Fortich vs.

Corona

Facts:

The subject of the controversy is an agricultural land in Sumilao, Bukidnon, measuring 144 hectares.
The municipality of Sumilao wanted to convert this into an agro-industrial land. In its Order dated March 29,
1996, Office of the President acceded to this conversion, and converted the whole 144 hectares to agro-
industrial land in order to attract investors. This order became final and executory. Feeling aggrieved, farmers
commenced a hunger-strike in protest of this ruling. The Office of the President wanted to appease the farmers,
hence, they issued a new resolution which was later called as “Win-Win Resolution’. They said that only 44
hectares will be converted into agro-industrial land and that the remaining 100 hectares will be distributed to
the farmers. The respondents filed a motion for reconsideration. Also, a Motion for Leave to Intervene was filed
by alleged farmer-beneficiaries claiming that they are real parties in interest as they were previously identified
by Depart of Agrarian Reform as agrarian reform beneficiaries on the 144-hectare property subject of this case.

Issue:
Whether or not said farmer-beneficiaries are real parties in interest in the case at bar

Held:

No. The movants are not real parties in interest in the case at bar.

In their motion, movants contend that they are the farmer-beneficiaries of the land in question, hence,
are real parties in interest. To prove this, they attached as Annex "I" in their motion a Master List of Farmer-
Beneficiaries. Apparently, the alleged master list was made pursuant to the directive in the dispositive portion
of the assailed "Win-Win" Resolution which directs the DAR "to carefully and meticulously determine who
among the claimants are qualified farmer-beneficiaries." However, a perusal of the said document reveals that
movants are those purportedly "Found Qualified and Recommended for Approval." In other words, movants
are merely recommendee farmer-beneficiaries.

The rule in this jurisdiction is that a real party in interest is a party who would be benefited or
injured by the judgment or is the party entitled to the avails of the suit. Real interest means
a present substantial interest, as distinguished from a mere expectancy or a future, contingent,
subordinate or consequential interest. Undoubtedly, movants interest over the land in question is a mere
expectancy. Ergo, they are not real parties in interest.