FACTS:

The petitioner, Laureno T. Angeles, and his late wife, Lizette Wijanco-Angeles, filed a complaint against the Philippine National Railways (PNR) and its corporate secretary, Rodolfo Flores. They sought the delivery of scrap/unserviceable rails and damages. The petitioner claimed that Lizette was authorized by Gaudencio Romualdez to withdraw the scrap/unserviceable rails awarded to him by PNR, but PNR suspended the withdrawal due to documentary discrepancies and alleged pilferages. The petitioner demanded a refund, which PNR refused, stating that some of the rails had already been withdrawn. The Regional Trial Court (RTC) dismissed the complaint, ruling that the spouses were not the real parties-in-interest. The Court of Appeals (CA) affirmed the trial court's decision, leading the petitioner to file a petition for review.

ISSUES:

RULING:

PRINCIPLES:

• Agency exists when one person binds himself to act for and in behalf of another, with the latter’s consent and authority.

• The liability of a third party in a contract is to the principal, not to the agent.

• An agent, as a general rule, cannot sue or be sued on a contract made in his capacity as an agent.

• An agent may sue on a contract made for his principal if he has been constituted as an assignee of such contract.