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Juasing Hardware v. Mendoza
115 SCRA 783 (1982)
G.R. No. L-55687 July 30, 1982
FACTS:
Juasing Hardware, alleging to be a single proprietorship duly organized and
existing under and by virtue of the laws of the Philippines and represented by its
manager Ong Bon Yong, filed a complaint for the collection of a sum of money against
Pilar Dolla.
In her Answer, Dolla stated that she has no knowledge about Juasing
Hardware's legal personality and capacity to sue as alleged in the complaint.
After Juasing Hardware had completed the presentation of its evidence and
rested its case, Dolla filed a Motion for Dismissal of Action for Juasing Hardware’s lack
of legal capacity to sue. Dolla contended that Juasing Hardware is a single
proprietorship, not a corporation or a partnership duly registered in accordance with
law, and therefore is not a juridical person with legal capacity to bring an action in
court. Juasing Hardware filed an opposition and moved for the admission of an
Amended Complaint to change the name.
Respondent Judge issued an Order dismissing the case and denying
admission of the Amended Complaint.
ISSUE:
W/N the Court properly dismissed the case filed by Juasing Hardware.
RULING:
No.
Juasing Hardware is definitely not a natural person; nor is it a juridical person
as defined in the New Civil Code of the Philippines thus:
Art. 44. The following are juridical persons:
(1) The State and its political subdivisions;
(2) Other corporations, institutions and entities for public interest or
purpose, created by law; their personality begins as soon as they have been
constituted according to law;
(3) Corporations, partnerships and associations for private interest or
purpose to which the law grants a juridical personality, separate and distinct
from that of each shareholder, partner or member.
There is no law authorizing sole proprietorships like Juasing Hardware to
bring suit in court. The law merely recognizes the existence of a sole proprietorship as
a form of business organization conducted for profit by a single individual, and
requires the proprietor or owner thereof to secure licenses and permits, register the
business name, and pay taxes to the national government. It does not vest juridical or
legal personality upon the sole proprietorship nor empower it to file or defend an
action in court.
Thus, the complaint in the court should have been filed in the name of the
owner of Juasing Hardware. The allegations in the body of the complaint would show
that the suit is brought by such person as proprietor or owner of the business
conducted under the name and style “Juasing Hardware.” The descriptive words
"doing business as Juasing Hardware' " may be added in the title of the case, as is
customarily done.
Be that as it may, Juasing Hardware's contention that respondent judge erred in
not allowing the amendment of the complaint to correct the designation of the party
plaintiff in the lower court, is impressed with merit. The defect of the complaint in the
instant case is merely formal, not substantial. Substitution of Juasing Hardware would
not constitute a change in the Identity of the parties. No unfairness or surprise to Dolla
would result by allowing the amendment, the purpose of which is merely to conform
to procedural rules or to correct a technical error.
Chang Kai Shek v. CA
172 SCRA 389 (1989)
FACTS:
Fausta F. Oh worked at the Chiang Kai Shek School since 1932 for a
continuous period of almost 33 years. And now, out of the blue, and for no apparent
or given reason, this abrupt dismissal.
Oh sued. She demanded separation pay, social security benefits, salary
differentials, maternity benefits and moral and exemplary damages. 1 The original
defendant was the Chiang Kai Shek School but when it filed a motion to dismiss on the
ground that it could not be sued, the complaint was amended. 2 Certain officials of
the school were also impleaded to make them solidarily liable with the school.
As a school, the petitioner was governed by Act No. 2706 as amended by C.A.
No. 180, which provided as follows:
Unless exempted for special reasons by the Secretary of Public Instruction,
any private school or college recognized by the government shall be

incorporated under the provisions of Act No. 1459 known as the Corporation
Law, within 90 days after the date of recognition, and shall file with the
Secretary of Public Instruction a copy of its incorporation papers and by-laws.
The Court of First Instance of Sorsogon dismissed the complaint.
ISSUE:
Whether or not a school that has not been incorporated may be sued by
reason alone of its long continued existence and recognition by the government,
HELD:
It is true that Rule 3, Section 1, of the Rules of Court clearly provides that
"only natural or juridical persons may be parties in a civil action." It is also not denied
that the school has NOT been incorporated. However, this omission should not
prejudice the private respondent in the assertion of her claims against the school.
Having been recognized by the government, it was under obligation to
incorporate under the Corporation Law within 90 days from such recognition. It
appears that it had not done so at the time the complaint was filed notwithstanding
that it had been in existence even earlier than 1932. The petitioner cannot now invoke
its own non-compliance with the law to immunize it from the private respondent's
complaint.
There should also be no question that having contracted with the private
respondent every year for thirty two years and thus represented itself as possessed of
juridical personality to do so, the petitioner is now estopped from denying such
personality to defeat her claim against it. According to Article 1431 of the Civil Code,
"through estoppel an admission or representation is rendered conclusive upon the
person making it and cannot be denied or disproved as against the person relying on
it."
As the school itself may be sued in its own name, there is no need to apply
Rule 3, Section 15, under which the persons joined in an association without any
juridical personality may be sued with such association. Besides, it has been shown
that the individual members of the board of trustees are not liable, having been
appointed only after the private respondent's dismissal.
It is easy to imagine the astonishment and hurt she felt when she was flatly
and without warning told she was dismissed. There was not even the amenity of a
formal notice of her replacement, with perhaps a graceful expression of thanks for her
past services. She was simply informed she was no longer in the teaching staff. To put
it bluntly, she was fired.
For the wrongful act of the petitioner, the private respondent is entitled to
moral damages. 14 As a proximate result of her illegal dismissal, she suffered mental
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anguish, serious anxiety, wounded feelings and even besmirched reputation as an
experienced teacher for more than three decades. We also find that the respondent
court did not err in awarding her exemplary damages because the petitioner acted in
a wanton and oppressive manner when it dismissed her. 15
WHEREFORE, the petition is DENIED. The appealed decision is AFFIRMED
except for the award of separation pay, which is reduced to P2,880.00. All the other
awards are approved. Costs against the petitioner.
This decision is immediately executory.
Hang Lung Bank Ltd. Vs Hon. Felintriye G. Saulog
201 SCRA 137
G.R. No. 73765, August 26, 1991
Belo, Abiera & Associates for petitioner.
Castelo Law Office for private respondent.
FACTS:
Petitioner Huang Lung Bank filed a collection suit in the Supreme Court of
Hongkong against Worlder and Cordova Chin San for sums of money due
the petitioner from the former on the basis of two (2) continuing guarantee
agreements petitioner entered into with Chin San in Hongkong. The foreign tribunal
ordered the payment to petitioner of the sum of HK$ 279,325 with interest and cost.
Demand was made in writing to Chin San at his Philippine address but no response
was made thereto. Hence, petitioner instituted in the RTC of Makati, Metro Manila
Branch CXLII an action for the enforcement of its claims against Chin San. Chin San
filed a motion to dismiss claiming petitioner had no legal capacity to sue and the venue
was improperly laid. The RTC granted the motion ruling that petitioner does not do
business in the Philippines and is barred from maintaining
suit pursuant to Sec. 14 of the General Banking Act. Its motion for reconsideration
having been denied, petitioner seeks the reversal of the orders of the RTC in a petition
for certiorari.
ISSUE:
Whether or not petitioner has the capacity to file the action below.
HELD:
Yes. A foreign corporation not licensed to do business in the Philippines may
not be denied the right to file an action in our courts for an isolated transaction in this

country. Petitioner foreign banking corporation may not be denied the privilege
of pursuing its claims against private respondent for a contract which was entered into
and consummated outside the Philippines. Otherwise, it will hamper the growth and
development of business relations between Filipino citizens and foreign nationals.
Worse, it would be allowing the law to serve as a protective shield for unscrupulous
Filipino citizens who have business relationships abroad. The complaint appears to be
one of the enforcement of the Hongkong
judgment because it prays for the grant of the affirmative relief given by said foreign
judgment. However, a foreign judgment may not be enforced if it is not recognized in
the jurisdiction where affirmative relief is being sought. Hence, in the interest
of justice, the complaint should be considered as a petition for the recognition of the
Hongkong judgment under Section 50 (b), Rule 39 of the Rules of Court in order that
the defendant, private respondent herein, may present evidence of lack
of jurisdiction, notice, collusion, fraud or clear mistake of fact and law, if applicable.
Commissioner of Customs v. KMK Gani
182 SCRA 591 (1990)
G.R. No. 73722, February 26, 1990
FACTS:
Two containers loaded with 103 cartons of merchandise covered by eleven
airway bills of several supposedly Singapore based consignees arrived at the Manila
International Airport. The cargoes were consigned to different entities, among others,
KMK Gani and Indrapal and Company, private respondents.
While the cargoes were at the MIA, a “reliable source” tipped the Bureau of
Customs that the said cargoes were going to be unloaded to Manila. The Suspected
Cargo and Anti-Narcotics (SCAN) dispatched an agent to verify the information.
The cargoes were seized and thereafter subject to Seizure and Forfeiture
proceedings for “technical smuggling.”
Atty. Armando Padilla entered his appearance for the consignees KMK and
Indrapal. Records of the case do not show any appearance of the consignees in person.
The Collector of Customs rules for the forfeiture of all the cargoes. Appeal was made
to the Commissioner of Customs. The Commissioner of Customs affirmed the finding
of the Collector of Customs of the presence of the intention to import the said goods
in violation of the dangerous drugs Act and a Central Bank Circular in relation to the
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Tariff and Customs Code. Appeal was then made to the Court of Tax Appeals, which
reversed the decision of the Commissioner of Customs. Hence this petition to review.
ISSUE:
WON private respondents failed to establish their personality to sue.
WON private respondents may sue within Philippine jurisdiction under the
“isolated transaction rule”.
HELD:
No foreign corporation transacting in the Philippines without a license, or its
successors or assigns, shall be permitted to maintain or intervene in any action, suit or
proceeding in any court or administrative agency of the Philippines; but such
corporation may be sued or proceeded against before Philippine courts or
administrative tribunals on any valid cause of action recognized under Philippine laws.
(Section 133, Corporation Code of the Philippines)However, a foreign corporation not
engaged in the in business in the Philippines may not be denied the right to file an
action in the Philippine courts for an isolated transaction. The fact that a foreign
corporation is not doing business in the Philippines must be disclosed if it desires to
sue in the Philippine courts under the “isolated transaction rule.” Without this
disclosure, the court may choose to deny it the right to sue.
In the case at bar, the private respondents KMK Gani and Indrapal aver that
they are “suing upon a singular and isolated transaction.” But they failed to prove their
legal existence or juridical personality as foreign corporations.
The “isolated transaction rule” refers only to foreign corporations. Here the
petitioners are not foreign corporations. They do not even pretend to be so. The first
paragraph of their petition, containing the allegation of their identities, does not even
aver their corporate character. On the contrary, KMK alleges that it is a “single
proprietorship” while Indrapal hides under the vague identification as a “firm”,
although both describe themselves. With the phrase “Doing business in accordance
with the laws of Singapore.

Merrill Lynch v. CA
GR 97816, 24 July 1992
211 SCRA 824
Facts:
On 23 November 1987, Merrill Lynch futures, Inc. (ML FUTURES) filed a
complaint with the Regional Trial Court at Quezon City against the Spouses Pedro M.
Lara and Elisa G. Lara for the recovery of a debt and interest thereon, damages, and
attorney's fees. In its complaint ML FUTURES described itself as (a) "a non-resident
foreign corporation, not doing business in the Philippines, duly organized and existing
under and by virtue of the laws of the state of Delaware, U.S.A.;" as well as (b) a
'futures commission merchant' duly licensed to act as such in the futures markets and
exchanges in the United States, . . . essentially functioning as a broker (executing)
orders to buy and sell futures contracts received from its customers on U.S. futures
exchanges."
In its complaint ML FUTURES alleged:
(1) that on 28 September 1983 it entered into a Futures Customer
Agreement with the spouses (Account 138-12161), in virtue of which it
agreed to act as the latter's broker for the purchase and sale of futures
contracts in the U.S.;
(2) that pursuant to the contract, orders to buy and sell futures contracts
were transmitted to ML FUTURES by the Lara Spouses "through the facilities
of Merrill Lynch Philippines, Inc., a Philippine corporation and a company
servicing ML Futures' customers;"
(3) that from the outset, the Lara Spouses "knew and were duly advised that
Merrill Lynch Philippines, Inc. was not a broker in futures contracts," and that
it "did not have a license from the Securities and Exchange Commission to
operate as a commodity trading advisor (i.e., "and entity which, not being a
broker, furnishes advice on commodity futures to persons who trade in
futures contracts");
(4) that in line with the above mentioned agreement and through said Merill
Lynch Philippines, Inc., the Lara Spouses actively traded in futures contracts,
including "stock index futures" for four years or so, i.e., from 1983 to October,
1987, there being more or less regular accounting and corresponding
remittances of money (or crediting or debiting) made between the spouses
and ML FUTURES;
(5) that because of a loss amounting to US $160,749.69 incurred in respect
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of 3 transactions involving "index futures," and after setting this off against
an amount of US $75,913.42 then owing by ML FUTURES to the Lara Spouses,
said spouses became indebted to ML FUTURES for the ensuing balance of US
$84,836.27, which the latter asked them to pay; and
(6) that the Lara Spouses however refused to pay this balance, "alleging that
the transactions were null and void because Merrill Lynch Philippines, Inc.,
the Philippine company servicing accounts of ML Futures, had no license to
operate as a "commodity and/or financial futures broker."
On the foregoing essential facts, ML FUTURES prayed (1) for a preliminary
attachment against the spouses' properties "up to the value of at least P2,267,139.50,"
and (2) for judgment, after trial, sentencing the spouses to pay ML FUTURES: (a) the
Philippine peso equivalent of $84,836.27 at the applicable exchange rate on date of
payment, with legal interest from the date of demand until full payment; (b) exemplary
damages in the sum of at least P500,000,00; and (c) attorney's fees and expenses of
litigation as may be proven at the trial. Preliminary attachment issued ex parte on 2
December 1987, and the spouses were duly served with summons.
The spouses filed a motion to dismiss dated 18 December 1987 on the
grounds that (1) ML FUTURES had "no legal capacity to sue" and (2) its "complaint
states no cause of action since it is not the real party in interest."
On 12 January 1988, the Trial Court promulgated an Order sustaining the
motion to dismiss, directing the dismissal of the case and discharging the writ of
preliminary attachment. It later denied ML FUTURES's motion for reconsideration, by
Order dated 29 February 1988. ML FUTURES appealed to the Court of Appeals. In its
own decision promulgated on 27 November 1990, the Court of Appeals affirmed the
Trial Court's judgment. Its motion for reconsideration having been denied, ML
FUTURES appealed to the Supreme Court on certiorari.
Issue:
Whether – in light of the fact that the Laras were fully aware of its lack of license
to do business in the Philippines, and in relation to those transactions had made
payments to, and received money from it for several years –the Lara Spouses are
estopped to impugn ML FUTURES capacity to sue them in the courts of the forum.

Held:
The Laras received benefits generated by their business relations with ML
FUTURES. Those business relations, according to the Laras themselves, spanned a
period of 7 years; and they evidently found those relations to be of such profitability
as warranted their maintaining them for that not insignificant period of time;
otherwise, it is reasonably certain that they would have terminated their dealings with
ML FUTURES much, much earlier. In fact, even as regards their last transaction, in
which the Laras allegedly suffered a loss in the sum of US$160,749.69, the Laras
nonetheless still received some monetary advantage, for ML FUTURES credited them
with the amount of US $75,913.42 then due to them, thus reducing their debt to US
$84,836.27. Given these facts, and assuming that the Lara Spouses were aware from
the outset that ML FUTURES had no license to do business in this country and MLPI,
no authority to act as broker for it, it would appear quite inequitable for the Laras to
evade payment of an otherwise legitimate indebtedness due and owing to ML
FUTURES upon the plea that it should not have done business in this country in the
first place, or that its agent in this country, MLPI, had no license either to operate as a
"commodity and/or financial futures broker."
Considerations of equity dictate that, at the very least, the issue of whether the
Laras are in truth liable to ML FUTURES and if so in what amount, and whether they
were so far aware of the absence of the requisite licenses on the part of ML FUTURES
and its Philippine correspondent, MLPI, as to be estopped from alleging that fact as a
defense to such liability, should be ventilated and adjudicated on the merits by the
proper trial court.
USA vs. Reyes
219 SCRA 192 (1993)
Topic: Parties
Facts:
This is a petition for certiorari and prohibition. Private respondent Montoya
is an American citizen who at the time material to this case, was employed an
identification checker at the US Navy exchange. Petitioner is likewise an American
citizen who was the activity exchange manager at JUSMAG headquarters. As a
consequence whereby her body and belonging were search after she had bought some
items from the retail store of the NEX JUSMAG while she was already at the parking
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area Montoya filed a complaint with the RTC of her residence – Cavite – against
Bradford for damages due to the oppressive and discriminatory acts committed by the
latter in excess of her authority as store manager of the NEX JUSMAG. She then prayed
for judgment ordering Bradford to pay her P500,000 as moral damages, P100,000 as
exemplary damages and reasonable attorney's fees plus the costs of the suit. Bradford
together with the government of US filed a motion to dismiss in support of the motion,
petitioners claimed that JUSMAG composed of an army, Navy and Air Gen established
under the Philippine US agreement. Thus, Bradford’s orders to have purchases of all
employees checked was made in the exercise of her duties as Manager.
Montoya filed a motion for preliminary attachment on the ground that
Bradford was about to depart from the country and was in the process of removing
and or disposing of her properties and filed her opposition to the motion to dismiss.
The trial court resolved both motion to dismiss and the motion for
preliminary attachment decreeing the issuance of a writ of attachment and directing
the sheriff to serve the writ immediately. Bradford received a copy of the decision and
she and the public petitioner filed with this court a petition for restraining order which
sought to have the trial court decision vacated and to prevent the execution of the
same. In the meantime, since there was no MR was filed, the order directing an entry
of final judgment was made.
Issues:
WON the trial court committed grave abuse of discretion in denying the
motion to dismiss based on effect that the suit against the public petitioner, a foreign
sovereign immune from suit.
Held:
Despite the fact that public petitioner was not impleaded as a defendant, it
nevertheless joined Bradford in the motion to dismiss without however first having
obtained leave of court to intervene therein. This was a procedural lapse, if not
downright improper legal tack. Since it was not impleaded as an original party, the
public petitioner could on its own volition join in the case by intervening therein. The
grant of intervention is discretionary upon the court and may be allowed only upon a
prior motion for leave with notice to all the parties in the action. Of course, Montoya
could have also impleaded the public petitioner as an additional defendant by
amending the complaint if she so believed that the latter is an indispensable or
necessary party.

The filing of the instant petition and the knowledge thereof by the trial court
did not prevent the latter from proceeding with Civil case no. 224 – 87. It is elementary
that the mere pendency of a special civil action for certiorari, commenced in relation
to a case pending before a lower court, does not interrupt the course of the latter
when there is no writ of injunction restraining it.
Flores v. Mallare-Philips
144 SCRA 377 (1986)
Topic: Parties
Facts
Flores sued the respondents for the collection of sum of money with the RTC
The first cause of action alleged in the complaint was against Ignacio
Binongcal for refusing to pay the amount of P11,643 representing cost of truck tires
which he purchased on credit from Flores on various occasions from August to
October, 1981;
The second cause of action was against respondent Fernando Calion for
allegedly refusing to pay the amount of P10,212 representing cost of truck tires which
he purchased on credit from pet on several occasions from March, 1981 to January,
1982.
Binongcal filed a motion to dismiss on the ground of lack of jurisdiction since
the amount of the demand against said resp was only P11,643.00, and under Section
19(8) of BP129 the RTC shall exercise exclusive original jurisdiction if the amount of
the demand is more than P20K.
Although another person, Fernando Calion, was allegedly indebted to pet in
the amount of P10,212.00, his obligation was separate and distinct from that of the
other resp. Calion joined in moving for the dismissal of the complaint.
RTC dismissed the complaint.
Issue
Whether or not the trial court correctly ruled on the application of the
permissive joinder of parties.
Ruling
The lower court has jurisdiction over the case following the "novel" totality
rule introduced in Section 33(l) of BP129 and Section 11 of the Interim Rules.
Section 33(l) of BP129
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That where there are several claims or causes of action between the same or
different parties, embodied in the same complaint, the amount of the
demand shall be the totality of the claims in all the causes of action,
irrespective of whether the causes of action arose out of the same or
different transactions. ...
Section 11 of the Interim Rules
Application of the totality rule. In actions where the jurisdiction of the court
is dependent on the amount involved, the test of jurisdiction shall be the
aggregate sum of all the money demands, exclusive only of interest and costs,
irrespective of WON the separate claims are owned by or due to different
parties. If any demand is for damages in a civil action, the amount thereof
must be specifically alleged.
Former rule under Section 88 of the Judiciary Act of 1948
Where there are several claims or causes of action between the same parties
embodied in the same complaint, the amount of the demand shall be the
totality of the demand in all the causes of action, irrespective of whether the
causes of action arose out of the same or different transactions; but where
the claims or causes of action joined in a single complaint are separately
owned by or due to different parties, each separate claim shall furnish the
jurisdictional test.
Under the present law, the two cases would be under the jurisdiction of the
RTC. Similarly, Brillo vs. Buklatan and Gacula vs. Martinez, if the separate claims against
the several defendants arose out of the same transaction or series of transactions and
there is a common question of law or fact, they would now be under the jurisdiction
of the RTC.
In cases of permissive joinder of parties, whether as plaintiffs or as
defendants, under Section 6 of Rule 3, the total of all the claims shall now furnish the
jurisdictional test. Needless to state also, if instead of joining or being joined in one
complaint separate actions are filed by or against the parties, the amount demanded
in each complaint shall furnish the jurisdictional test.
The lower court correctly held that the jurisdictional test is subject to the
rules on joinder of parties pursuant to Section 5 of Rule 2 and Section 6 of Rule 3 of
the Rules of Court and that, after a careful scrutiny of the complaint, it appears that
there is a misjoinder of parties for the reason that the claims against resps Binongcal
and Calion are separate and distinct and neither of which falls within its jurisdiction.

Ralla v. Ralla
199 SCRA 495
G.R. No. 78646 July 23, 1991
PABLO RALLA, substituted by his wife and co-defendant CARMEN MUÑOZ-RALLA, and
his legal heirs, HILDA RALLA-ALMINE, BELISTA, RENE RALLA-BELISTA and GERARDO M.
RALLA, petitioners,
vs.
PEDRO RALLA, substituted by his legal heirs, LEONI, PETER, and MARINELA all
surnamed RALLA, and COURT OF APPEALS, respondents.
Case Summary:
Respondent Pedro filed a complaint to annul the deed of sale of several
parcels of land executed by his deceased father in favor of his brother Pablo on the
ground that it was simulated. In a separate proceeding, Pedro’s disinheritance was
approved. Resolving the issue on the validity of the deed of sale, the RTC ruled that
the sale was valid. CA ruled that the sale was invalid. The SC did not rule on the
invalidity o fthe sale because of one obstacle
– v RTC
PEDRO did not have a legal personality to assail the validity of the deed of the sale.
He was disinherited, therefore not a party-in-interest.
Doctrine/s:
Real party-in-interest is the party who stands to be benefitted or injured by
the judgment or the party entitled to the avails of the suit.
“Interest” means material interest, an interest in issue and to be affected by
the decree, as distinguished from mere interest in the question involved, or a mere
incidental interest. As a general rule, one having no right or interest to project cannot
invoke the jurisdiction of the court as a party-plaintiff in the action.
Action Before SC:
“This is a petition for review under Rule 45 of the Rules of Court”
Facts:
Rosendo Ralla had two sons, Pablo and Pedro. The father apparently loved
the former but not the latter.
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Rosendo executed a will disinheriting Pedro and leaving everything he owned
to Pablo, to whom he said he had earlier sold a part of his property for P10,000.00.
Rosendo himself filed for the probate of the will but pendente lite died on October 1,
1960.
On November 3, 1966, the probate judge converted SP 564 into an intestate
proceeding.
The last will and testament of Rosendo Ralla was allowed on June 7, 1982.
On October 20, 1982, the disinheritance of Pedro was disapproved. Pablo
elevated the October 20, 1982 order to the Court of Appeals
In a decision dated July 25, 1986, CA Reversed the trial court and reinstated
the disinheritance clause after finding that the requisites of a valid disinheritance had
been complied with in the will. The appellate court noted that Pedro had threatened
to kill his father, who was afraid of him and had earlier sued him for slander and grave
oral defamation.
v SC
Ø Pedro assailed the July 25, 1986 order of CA - dismissed
Ø MOR was denied with finality
Ø Pedro had filed on May 19, 1972, a complaint to annul the
transaction the deed of sale executed by Rosendo Ralla in favor of
Pablo over 149 parcels of land on the ground that it was simulated.
Ø declared the sale null and void
Ø upon Pablo’s MOR, judge held the deed of sale to be valid.
v CA
Ø Upon Pedro’s appeal, reinstated the original decision invalidating
the deed of sale.
v SC
Ø Pablo elevated CA’s decision
ISSUE:
WON sale executed by Rosendo Ralla in favor of Pablo over 149
parcels of land is valid
RULING:
No.
 Page |8

The decision of the CA (previous case) approved the disinheritance of Pedro

Ralla and the decision has long since become final. Since then, Pedro Ralla no longer
had the legal standing to question the validity of the sale executed by Rosendo in favor
of his other son Pablo.
The real party-in-interest is the party who stands to be benefited or injured
by the judgment or the party entitled to the avails of the suit. "Interest" within the
meaning of the rule means material interest, an interest in issue and to be affected by
the decree, as distinguished from mere interest in the question involved, or a mere
incidental interest. As a general rule, one having no right or interest to protect cannot
invoke the jurisdiction of the court as a party-plaintiff in an action.
Legally speaking, Pedro Ralla was a stranger to the transaction as he did not
stand to benefit from its annulment. His disinheritance had rendered him hors de
combat.
Reversed CA, complaint dismissed.