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V-GENT v. MORNING STAR TRAVEL

FACTS:

Petitioner V-Gent, Inc. bought twenty-six (26) two-way plane tickets from respondent Morning Star Travel and Tours, Inc. In June and September 1998, V-Gent returned fifteen (15) unused tickets to Morning Star and demanded a refund. Morning Star refunded only six (6) tickets and refused to refund the remaining nine (9) tickets. V-Gent filed a money claim against Morning Star for the unrefunded amount. The Metropolitan Trial Court (MeTC) dismissed the complaint, stating that V-Gent was the real party-in-interest but failed to prove its claim. V-Gent appealed to the Regional Trial Court (RTC), which granted the appeal and ordered Morning Star to pay. Morning Star filed a petition for review with the Court of Appeals (CA), which granted the petition, dismissing V-Gent's complaint. V-Gent filed a motion for reconsideration, which the CA denied. Hence, the present petition for review on certiorari. V-Gent argues that it is the real party-in-interest and Morning Star is estopped from questioning its legal standing, while Morning Star asserts that V-Gent is not the real party-in-interest and that it had no obligation to appeal the MeTC judgment.

ISSUES:

  1. Whether V-Gent is the real party-in-interest in filing the complaint.

  2. Whether Morning Star is estopped from questioning V-Gent's legal standing to file the complaint.

RULING:

  1. The Court of Appeals (CA) held that V-Gent is not a real party-in-interest because it merely acted as an agent of the passengers who bought the tickets from Morning Star with their own money. The CA dismissed V-Gent's complaint. V-Gent argues that the CA erred in ruling that it is not the real party-in-interest and that Morning Star is already estopped from questioning V-Gent's legal standing to file the complaint. Morning Star counters that it had no obligation to appeal the MeTC judgment dismissing the complaint in its favor, and that the real parties-in-interest are the passengers named on the tickets.

PRINCIPLES:

  • A real party-in-interest is the party who stands to be benefited or injured by the judgment in the suit, or the party entitled to the avails of the suit.

  • An agent who acts for and is paid by a disclosed principal is not a party to the contract between the principal and the third person and does not assume any personal liability to the third person, except when the parties intend to bind the agent personally.