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73 Ralla v.

Ralla
GR. No. 78646 (1991)
Cruz, J. / Tita K

Subject Matter: Rule 3; party-in-interest

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 of
the sale because of one obstacle – PEDRO did not have a legal personality to assail the validity of the deed of
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”

Parties:
Petitioner Pablo Ralla, substituted by his wife and co-defendant Carmen Munoz-
Ralla, and his legal heirs, Hilda Ralla-Almine, Belista, Rene Ralla-
Belista and Gerardo M. Ralla

Respondent/Defendant/Appellee Pedro Ralla, substituted by his legal heirs Leoni, Peter, and Marinella,
all surnamed Ralla, and Court of Appeals

Antecedent Facts:
1. Petioner Pablo and Respondent Pedro are sons of Rosendo.
2. Rosendo apparently loved Pablo but not Pedro, that Rosendo sold over 149 parcels of land to
petitioner Pablo for P10,000.
3. Rosendo also executed a will disinheriting respondent Pedro and living everything he owned to
petitioner Pablo.
The ground for disinheriting Pedro was that he allegedly threatened to kill his father, and so his
father sued him for slander and grave oral defamation.

The probate of the will (you can SKIP this part but bear in mind that Pedro was disinherited):
4. October 22, 1982:
The probate court allowed his last will and testament but disapproved the disinheritance.
5. July 25, 1986:
CA reversed the trial court and reinstated the disinheritance clause since the requisites for a valid
disinheritance were complied with in the will.
6. April 26, 1987:
The SC ruled that the CA decision is not tainted with grave abuse of discretion as the petition was filed
late, because Pablo filed a motion to extend period instead of moving for reconsideration or appeal.
The motion did not interrupt the running of the 15-day period of appeal, and sadly the motion to extend
period was DENIED.
7. October 26, 1987:
The motion to for reconsideration was denied with finality due to tardiness (counsel’s fault tsk tsk!).
Counsel are expected to be abreast of current developments in law and jurisprudence!
(MAIN TAKEAWAY in this proceeding: PEDRO is DISINHERITED; approval of disinheritance
became final and executory.)

The annulment of the deed of sale (simultaneous to with probate proceeding)


1st Level Court Proceedings
RTC
1. Action: Respondent Pedro filed a complaint to annul the sale of parcels of land to Pablo on the
ground that it was simulated.
2. Ruling: TC declared the sale null and void.
3. MR: However, the judge completely reversed himself in the MR resolution and held the deed of sale
to be valid.
(SC’s side note comment: intriguing how the RTC reversed itself on the basis of the same evidence and jurisprudence)

Appellate Court Proceedings


CA.
1. CA set aside the MR decision and reinstated the invalidity of the sale.

Issues:
1. WON the CA is correct in annulling the deed of sale executed by Rosendo in favor of Pablo –NO

Ratio:

No – The SC cannot make a decision on the validity of the deed of sale because Pedro Ralla had no legal
standing to question the validity of the transaction because he was disinherited.
 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.
o Petitioner Pablo Ralla, as the sole heir, had the right to inherit the totality of his father’s
estate after payment of all its debts.
o Even if the deed of sale was invalid, the subject parcels of land would still go to Pablo.
o The subject 149 parcel of land was part of Rosendo’s own property (not a conjugal property)
which, according to the will, was sold earlier to Pablo.

o The Court also noted the lackadaisical1 attitude of Pedro’s heirs after the approval of Pedro’s
disinheritance. They no longer submitted a memorandum despite several opportunities given by
the SC.

o Hence, as a validly disinherited heir, and not claiming to be a creditor of the deceased
father, Pedro Ralla had no legal personality to question the deed of sale between his
brother, Pablo and his father, Rosendo. Legally speaking, Pedro Ralla was a stranger to
the transaction as he does not stand to benefit from its annulment.

Dispositive: Wherefore, the decision of the respondent court is set aside.

1 Or lack of interest