Alonso v.

Villamor

(PRIEST)

FACTS: Defendants were members of the municipal board of the municipality of Placer. They wrote a
letter addressed to the plaintiff who at that time was the priest in charge of the church. The contents of
the letter basically stated that there was an order from the provincial fiscal saying that cemeteries,
convents and other buildings erected on land belonging to the town belong to the town. As such, they
are notifying the priest that all revenues and products of the church must be turned over to the treasury
of the municipality. All alms given by churchgoers and devotees should be turned into the municipal
treasury.

Two weeks after, the defendants took possession of the church and all of the personal properties
contained therein. The plaintiff, as the priest and as the person in charge thereof, made protests that
went unheeded. Hence, an action was brought by him to recover from the defendants the value of the
articles and the rental value of the church.

The lower court ruled in favor of the plaintiff. In the defendants’ appeal, one of the defenses presented
was that the plaintiff was not the real party in interest. The defendants assert that the court erred in
permitting the action to be brought and continued in the name of the plaintiff, Tomas Villamor, instead
of in the name of the Bishop of the Diocese within which the church was located or in the name of the
Roman Catholic Church itself.

ISSUE: Whether or not the formal/technical defect raised by defendants constitutes a ground for the
reversal of the court’s decision

HELD: No. The Supreme Court allowed the substitution of the plaintiff as the party in interest. Sec. 503
of the Code of Civil Procedure provides that, “No judgment shall be reversed on formal or technical
grounds, or for such error as has not prejudiced real rights of the excepting party.” Sec. 110 of the same
code also provides that in furtherance of justice, the court is empowered to allow a party to amend any
pleading or proceeding at any stage of the action.

In this case, it is undoubted that the bishop of the diocese or the Roman Catholic Apostolic Church itself
is the real party in interest. The plaintiff asserted the same in the complaint, and maintained such
assertion all through the record. He claimed no interest whatsoever in the litigation. The substitution,
then, of the name of the bishop of the diocese as party plaintiff, is in reality not a substantiation of the
identity of another but is simply to make the form express the substance of that is already there.

The error in this case is purely technical. To take advantage of it for other purposes than to cure it, does
not appeal to a fair sense of justice. A litigation is not a game of technicalities in which one, more deeply
schooled and skilled in the subtle art of movement and position, entraps and destroys the other. It is,
rather, a contest in which each contending party fully and fairly lays before the court the facts in issue
and then, brushing aside as wholly trivial and indecisive all imperfections of form and technicalities of
procedure, asks that justice be done upon the merits. Lawsuits, unlike duels, are not to be won by a
rapier's thrust. The Court went on to say that the purpose of processes, pleadings, their forms and
contents is to facilitate the application of justice to the rival claims of the contending parties. They were
created not to hinder and delay, but to facilitate and promote, the administration of justice.