Vidal v. Escueta, G.R. No. 156225, Real Parties in Interest

Real parties in interest.

Facts: An estate- a parcel of land and the house thereon, was leased to Rainier Llanera, who sublet the same to 25 persons. When the owners decided to sell the property, Ma. Teresa Escueta, atty-in-fact and as a co-owner of the property, filed an ejectment case against Llanera and the sub-lessees before the Lupon of Barangay. On May 1999, Escueta and Llanera, and the sub-lessees, executed an “Amicable Settlement,”  where they agreed among others that lessee and sub-lessee shall vacate the property on or before December 1999. The parties did not repudiate the amicable settlement within ten days from the execution thereof. Meantime the property was sold but the full payment was not yet handed to the sellers since the lessee and the sublessees have not yet vacated the property. Later, Llanera and twenty of the sub-lessees also vacated the property except petitioners who remained in the property and refused to vacate the property despite extensions given to them, thus, prompting Escueta to file a verified “Motion for Execution” against the sub-lessees with the MTC for the enforcement of the amicable settlement and the issuance of a writ of execution. The Motion was denied. The court held that the plaintiff was not the real party-in-interest as the subject property had already been sold. Is the ruling correct? Explain.

Held: No.

 1.) The respondent is the real party-in-interest to enforce amicable settlement. (See Rule 3, Section 2 of the Rules of Court). The party-in-interest applies not only to the plaintiff but also to the defendant.  “Interest” within the meaning of the rules 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. A real party in interest is one who has a legal right. Since a contract may be violated only by the parties thereto as against each other, in an action upon that contract, the real parties-in-interest, either as plaintiff or as defendant, must be parties to the said contract. The action must be brought by the person who, by substantive law, possesses the right sought to be enforced. In this case, the respondent was the party in the amicable settlement.  She is the real party-in-interest to enforce the terms of the settlement because unless the petitioners vacate the property, the balance of the purchase price will not be paid to them. (Vidal v. Escueta, G.R. No. 156225, December 10, 2003).