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SPS. ANT v. VICTOR LIMBARING

FACTS:

In this case, Sabas Limbaring divided Lot 2325-D into two lots and sold them to Jennifer Limbaring and Sarah Jane Limbaring. Transfer Certificates of Title (TCT) were issued in their names. Percita Oco, daughter of Sabas Limbaring, filed a case against her uncle (the father of Jennifer and Sarah Jane) for perjury and falsification of documents. During a pre-litigation conference, Percita agreed to pay her uncle P25,000 for the expenses of transferring the titles back to her name. However, after the titles were transferred, Percita did not pay the agreed amount. As a result, her uncle filed a complaint for rescission of the sales contracts and recovery of possession and ownership of the lots.

The defendants, Spouses Anthony and Percita Oco, filed a motion to dismiss, arguing that the uncle was not the real party in interest. The trial court initially denied the motion to dismiss but later granted the defendants' demurrer to evidence and dismissed the complaint. The trial court ruled that the uncle was not the real party in interest.

The Court of Appeals, however, reversed the decision of the trial court. It held that the uncle was a real party in interest and that the P25,000 was part of the consideration for the reconveyance of the lots.

ISSUES:

  1. Whether respondent was a real party in interest in the suit to rescind the Deeds of Reconveyance.

RULING:

  1. The Supreme Court ruled that respondent was not a real party in interest in the suit to rescind the Deeds of Reconveyance. The respondent, who was not a party to the contracts being sued upon, was not able to prove material interest in the litigation. The trial court dismissed the action to rescind the contracts and the Supreme Court affirmed the dismissal.

PRINCIPLES:

  • Every action must be prosecuted or defended in the name of the real party in interest.

  • In cases involving a deed of sale between a parent and a child where the purchase price is paid by the parent, there is a legal presumption that it is a gift in favor of the child. Any allegation to the contrary must be proven by clear and satisfactory evidence.