Emmanuel Ortega

UA&P LAW Agency, Trust, and Partnerships

WILLIAM UY and RODEL ROXAS, petitioners,
vs.
COURT OF APPEALS, HON. ROBERT BALAO and NATIONAL HOUSING
AUTHORITY, respondents.
FACTS:
Petitioners, William Uy and Rodel Roxas are agents authorized to sell
eight parcels of land, located in Benguet, by the owners thereof. Petitioners offered
to sell the lands to respondent, National Housing Authority (NHA) On February 14,
1898 the NHA approved the acquisiton of said lands however, they only paid for five
because of a report that the remaining area is located at an active landslide area.
On November 22, 1991, the NHA cancelled the sale over the three parcels of land.
On March 9, 1992, petitioners filed before the RTC of Quezon City a complaint for
damages against NHA. The RTC rendered a decisions declaring the cancellation of
the contract by NHA to be justified and awarded damages to Uy and Roxas. Upon
appeal by Petitioners, the CA entered a new decision dismissing the compaint and
removing the award for damages. The CA noted that petitioners were mere
attorneys-in-fact and therefore, not the real parties-in-interest.
ISSUE:
THE CASE

WHETHER OR NOT PETITIONERS ARE REAL PARTIES-IN-INTEREST IN

HELD: No.
Petitioners claim that they lodged the complain not in behalf of their principals but
in their own name as agents directly damaged by the termination of the contract.
Petitioners are not parties to the contract of sale between their principals and NHA.
They are mere agents of the owners of the land. As agents, they only render some
service or do something in representaiton or on behalf of their principals. The
rendering of such service did not make them parties to the contracts of sale they
executed in behalf of the principals.
The instant petition is denied.

Emmanuel Ortega
UA&P LAW Agency, Trust, and Partnerships

G.R. No. 150128 August 31, 2006

LAUREANO T. ANGELES, Petitioner,
vs.
PHILIPPINE NATIONAL RAILWAYS (PNR) AND RODOLFO
FLORES, 1Respondents.
FACTS: On May 5, 1980, respondent Philippine National Railways (PNR) informed
Gaudencio Romualdez that it has accepted his offer to buy PNRs
scrap/unserviceable rails in Del Carmen and Lubao, Pampanga. After paying the
purchase price, Romualdez addressed a letter to PNR authorizing Lizette R. Wijanco
- Angeles to be his lawful representative in the withdrawal of the scrap rails. Lizette
requested the PNR to transfer scrap rails in Pampanga but it was not ready for
hauling. The PNR instead granted Lizette to withdraw scrap rails from Tarlac instead.
However, they suspended such withdrawal in view of internal issues regarding the
Tarlac properties. The spouses Angelese demanded a refund but PNR refused to pay.
On August 10, 1988, the spouses Angeles filed a suit against the PNR for specific
performance and damages before the RTC in Quezon City. Later, Lizette W. Angeles
passed away and was substituted by her heirs. The RTC dismissed the case since
the spouses Angeles were not real parties-in-interest. The CA affirmed such
decision.
ISSUE: WHETHER OR NOT THE SPOUSES ANGELES ARE REAL PARTIES-IN-INTEREST
IN THE CASE
HELD: No.
Lizette was not an assignee but merely an agent whose authority was limited to the
withdrawal of the scrap rails, hence without personality to sue. Where agency
exists, the third partys (PNR) liability on the contract is to the principal (Romualdez)
and not to the agent (Lizette) and the relationship of the third party to the principal
is the same as that in a contract in which there is no agent. The words of
Romualdezs letter to PNR was very clear
I have authorized the bearer, Lizetter R. Wijanco (Angeles) xxx to by my lawful
representative in the withdrawal of the scrap/unserviceable rails awarded to me.
It cannot be over empasized that Roumualdezs use of the active verb authorized
instead of assigned, indicated an intent on his part to keep and retain his interest
in the subject matter.
The petition is denied.