Delizo, Mark Alvin

Uy vs CA, G.R. No. 120465. September 9, 1999.

Topic: Representative parties

Ponente: Justice Kapunan

Facts
Petitioners were authorised by the owners of the lands in Benguet to
NHA, pursuant to such, the NHA passed a resolution approving the
acquisition of such lands and as such the deed of absolute sale was executed
by the parties. However only 5 of the 8 parcels of land were paid for by the
NHA, the reason for such is that the DENR reported that such portions is not
suited for the housing project due to it being located in a landslide prone
area.

NHA due to such issued a resolution cancelling the sale of 3 parcels

of land. NHA offered P1.225 million as danos perjuicos to the landowners.
Petitioners filed before the RTC of Quezon City for a complaint for damages
against NHA and its General Manager. RTC rendered a decision granting
the cancellation of the sale and awarded damages to the petitioners for the
amount of the danos offered. CA reversed the decision on appeal by the
petitioners, according to the CA there was no reason to award the damages
to petitioners as they are merely attorneys-in-fact and not the real party in
interest.

Issue: WON the petitioners are the real party in interest in this case.

Ruling
No. Petitioners are not a real party in interest. Section 2, Rule 3 of the
Rules of Court requires that every action must be prosecuted and defended
in the name of the real party-ininterest. 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 the issue and to be affected by the decree, as
distinguished from mere interest in the question involved, or a mere
incidental interest.

Petitioners are not parties to the contract of sale between their

principals and NHA. They are mere agents of the owners of the land subject
of the sale. As agents, they only render some service or do something in
Delizo, Mark Alvin

representation or on behalf of their principals. The rendering of such service

did not make them parties to the contracts of sale executed in behalf of the
latter. Since a contract may be violated only by the parties thereto as against
each other, the real parties-in-interest, either as plaintiff or defendant, in an
action upon that contract must, generally, either be parties to said contract.