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SIGUION REYNA MONTECILLO v. NORMA CHIONLO-SIA

FACTS:

The petitioner, Siguion Reyna Montecillo & Ongsiako Law Offices (SRMO), acted as counsel for Remedios N. Rodriguez in an action for the intestate settlement of her deceased husband's estate. During the proceeding, Remedios requested a widow's allowance, which was initially denied by the Regional Trial Court (RTC) but later granted by the Court of Appeals (CA). While the case was pending before the CA, Remedios sold all her rights and interests in the estate to Remigio M. Gerardo through a Deed of Sale of Inheritance. As a condition of the sale, Remedios executed a special power of attorney (SPA) authorizing Gerardo to receive any property or funds due to her. Gerardo designated SRMO as his substitute attorney. Subsequently, SRMO filed a motion with the RTC for the payment of the widow's allowance, which was granted and the amount was remitted to SRMO. The RTC also approved a partial project of partition of the estate. However, Remedios later filed a motion questioning the partition and demanded that SRMO return the amount it received. Before the motion could be resolved, Remedios filed a notice of withdrawal. Nevertheless, the RTC ordered SRMO to reimburse the estate. SRMO sought to be excused from reimbursing, arguing that it was acting on behalf of Gerardo, who purchased Remedios' interests. The RTC denied SRMO's motion, prompting it to file a petition for certiorari with the CA which was denied. SRMO now seeks the reversal of the CA's ruling from the Supreme Court.

ISSUES:

  1. Whether a non-party in the proceedings before the lower court has standing to question the order or decision of the said court before the appellate court via certiorari.

  2. Whether SRMO, as counsel for Remedios or Gerardo, can be held personally liable for the order of reimbursement.

  3. Whether SRMO has legal standing to challenge the orders of the RTC.

  4. Whether SRMO is the real party in interest in the case.

RULING:

  1. Under normal circumstances, a person not a party to the proceedings in the trial court cannot maintain an action for certiorari in the Court of Appeals or the Supreme Court to have the order or decision of the trial court reviewed. However, in this case, a less stringent application of the rule is warranted due to the peculiar facts of the case. Therefore, SRMO, a non-party in the proceedings before the lower court, has standing to question the order of reimbursement via certiorari.

  2. SRMO, as counsel for Remedios or Gerardo, cannot be held personally liable for the order of reimbursement. Under the law of agency, an agent is not personally liable for the obligations of the principal unless he performs acts outside the scope of his authority or he expressly binds himself to be personally liable. In this case, SRMO acted within the bounds of the authority issued by Gerardo to receive the payment. The order of reimbursement should have been directed to the party who ultimately benefited from any unwarranted payment, not to his lawyer.

  3. Yes, SRMO has legal standing to challenge the orders of the RTC. Unlike the case of Tang, where the petitioners were neighboring lot owners and their interest in the case was merely incidental, SRMO has a direct interest in the case. As the counsel/agent of Gerardo, it received the subject money and is being required to reimburse it from its own coffers. The highly fiduciary relationship between counsel and client makes SRMO a party with a direct interest to challenge the RTC's order.

  4. Yes, SRMO is the real party in interest in the case. A real party in interest is one "who stands to be benefited or injured by the judgment in the suit, or the party entitled to the avails of the suit." SRMO stands to be injured by the RTC's order of reimbursement since it is being made to return money received on behalf of, and already accounted to, its client.

PRINCIPLES:

  • The general rule is that a person not a party to the proceedings in the trial court cannot maintain an action for certiorari in the appellate court. However, there are exceptions to this rule.

  • An agent is not personally liable for the obligations of the principal unless he performs acts outside the scope of his authority or he expressly binds himself to be personally liable.

  • The Rules of Court do not require counsels of parties to report any transfer of interest. Unless the court upon motion directs the transferee pendente lite to be substituted, the action is simply continued in the name of the original party.

  • Technical rules of procedure should be used to promote, not frustrate, the cause of justice. Rules of procedure are tools designed to facilitate the attainment of justice, and their strict and rigid application may have to give way to the need to dispense substantial justice.

  • The right to support is a purely personal right that cannot be subject to attachment or execution. However, support in arrears may be compensated, renounced, or transmitted by onerous or gratuitous title.

  • The principle of relativity of contracts states that a contract is binding only between the parties thereto, and they alone acquire rights and assume obligations thereunder. Any ruling that affects the enforceability of a contract will have an effect on the rights of the parties to the contract.