G.R. No. 150629.

June 30, 2004 An examination of the petition, its body, however, gave no details as to the juridical
personality and addresses of these alleged associations except for Acebedo Optical
Tichangco vs. Enriquez Co., Inc.

Issue:
Facts:
WON private respondents have locus standi in this case.
Petitioner Tichangco filed a land title verification request with the LRA but it was
prompted by an alleged claim of ownership of a certain Manotok over the land Ruling:
which the petitioners occupy.
No. Only natural and juridical persons or entities authorized by law may be parties
In their Motion for Reconsideration, petitioners raised the minority of the land in a civil action and every action must be prosecuted or defended in the name of the
registration applicants—Severino, Benita, Ambrosio and Ricardo, all surnamed real party in interest. Under Article 44 of the Civil Code, an association is
Manotok—as an additional ground to nullify OCT No. 820. Ostensibly, they had considered a juridical person if the law grants it a personality separate and distinct
filed their application without the assistance of a legally appointed guardian. The from that of its members.
CA, however, denied petitioners’ Motion for Reconsideration for lack of merit.
In the case at bench, since OPAP, COA, ACMO, and SMOAP were not shown to be
Hence, this petition. juridical entities, they cannot be deemed real parties in interest. Moreover, since
the names of private respondents Miguel Acebedo, Miriam F. Llave, and Republica
Issue: A. Panol do not appear in the registration books of the Board of Optometry as
WON the contention of the petitioner was correct. authorized optometry practitioners in the Philippines, they do not have the
requisite personal and substantial interest in the case. Hence, they are deemed to
Ruling: be devoid of legal personality to bring an action

No. The mere failure to mention on the title the names of the legal guardians does
not necessarily imply their absence during the actual land registration proceedings.
Besides, the absence of legal guardians cannot be used as a basis for depriving G.R No. L-34532. December 19, 1980
minors of benefits that have accrued to them. If at all, it could be a ground to Pasay Law and Conscience Union, Inc. vs. Cuneta
invalidate an imprudent attack against their interest, not to deprive them of any
advantage or gain. Facts:

G.R. No. 122241. July 30, 1996 Petitioner COP Siquijor together with PLACU, question the validity of
Memorandum Order No. 1 issued by respondent mayor, assigning the petitioner
Board of Optometry vs. Colet Chief of Police of Pasay City with the office of respondent Mayor Pablo Cuneta as
Facts: consultant on police matter, and Memorandum Order No. 10 designating
respondent Carlos T. Galvez as respondent mayor’s representative to take charge
Republic Act No. 8050, entitled “An Act Regulating the Practice of Optometry of all his orders relating to all police matters to render more effective his power of
Education, Integrating Optometrists, and for Other Purposes,” otherwise known as control and supervision over the Pasay police force, as acts allegedly contrary to
the Revised Optometry Law of 1995, was approved into law on 7 June 1995. law intended to deprive petitioner Roland C. Siquijor of his lawful appointment and
position as qualified Chief of Police of Pasay City without lawful cause and due
The private respondents filed with the Regional Trial Court (RTC) of Manila a process of law.
petition for declaratory relief and for prohibition and injunction, with a prayer for
a temporary restraining order. However, after questioning the validity of petitioner’s appointment before the CSC,
he learned that CSC revoked the approval of such appointment. Respondents now
claim that since petitioner Chief of Police’s appointment is void, petitioner has no
personality before the Court.

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Issue: sue or file or defend an action. There is no law authorizing sole
WON petitioners lack legal interest in this case. proprietorship to file a suit. A sole proprietorship does not possess a
juridical personality separate and distinct from the personality of
Ruling:
the owner of the enterprise.
Petitioner PLACU, together with the real party in interest, petitioner Chief of
Police, is not disqualified to appear as petitioner in this case, because as a non- In this case, the IMP is not a corporation and does not have a
profit, civic and nonpartisan organization, like the PHILCONSA, it is merely juridical personality that could enable it to be a party defendant in
interested in upholding the rule of law. the RTC. It is BMPI which has the juridical personality to be sued
by the respondent as the plaintiff in the RTC.
G.R. No. 154630. May 6, 2005
G.R. No. 129008. January 13, 2004
Berman Memorial Park, Inc. vs. Cheng
Rioferio vs. Court of Appeals
Facts:
Facts:
In 1994, Cheng’s wife, died. He purchased from BMPI a memorial
lot in the IMP for the interment of his wife He and BMPI executed Alfonso Orfinada, Jr. died without a will leaving several personal
At-Need Purchase Agreement. Sometime in May 1994, Cheng and real properties located in different locations. He also left a
purchased from the BMPI a bigger lot in the IMP where the remains widow Esperanza P. Orfinada, whom he married and with whom he
of his wife would be transferred. Cheng and BMPI executed then a had seven children who are the herein respondents. The decedent
Pre-Need Purchase Agreement for the upgrade. left in mourning his paramour and their children who are the
petitioners.
Subsequently, Cheng received a statement of account from BMPI
showing that he still had a balance of P32,375.00. Cheng, through In 1995, respondents discovered that petitioners executed
counsel, informed BMPI that he had, in fact, made an overpayment. an Extrajudicial Settlement of Estate of a Deceased Person with
Quitclaim involving the properties of the estate of the decedent
Cheng filed a complaint against the IMP, not against BMPI, and
located in Dagupan City in favor of petitioners and also found out
Luisa Chong in the Regional Trial Court (RTC) for specific
that petitioners were able to obtain a loan of P700,000.00 from the
performance with damages.
Rural Bank of Mangaldan Inc. by executing a Real Estate
Issue: Mortgage over the properties subject of the extrajudicial settlement.
Whether or not the IMP has the capacity to sue as petitioner and be Respondents filed a Complaint for the Annulment/Rescission of
sued as defendant in the RTC; and whether or not BMPI is an Extra Judicial Settlement of Estate of a Deceased Person with
indispensable party in the RTC, and in this case. Quitclaim, and Other Related Documents with Damages against
petitioners.
Ruling:
Petitioners filed their Answer to the said contending that the
The rule is that only natural or juridical persons or entities
property subject of the contested deed of extra-judicial settlement
authorized by law may be parties in a civil case. A sole
originally belongs Teodora Riofero’s parents and that the titles
proprietorship is not vested with juridical personality and cannot
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thereof were delivered to her as an advance inheritance, but the
decedent had managed to register them in his name. Petitioners
also raised the affirmative defense that respondents are not the real
parties-in-interest but rather the Estate of Alfonso Orfinada, Jr. in
view of the pendency of the administration proceedings

The lower court denied the motion on the ground that respondents,
as heirs, are the real parties-in-interest especially in the absence of
an administrator who is yet to be appointed in S.P. CA affirmed the
TC’s decision. A Motion for Reconsideration was filed by petitioners
but it was denied. Hence, the petition before this Court.

Issue:

Whether the heirs may bring suit to recover property of the estate
pending the appointment of an administrator is the issue in this
case.

Ruling:

Yes. The heirs without doubt have legal personality to bring suit in
behalf of the estate of the decedent in accordance with the provision
of Article 777 of the New Civil Code “that (t)he rights to succession
are transmitted from the moment of the death of the decedent.” The
provision in turn is the foundation of the principle that the property,
rights and obligations to the extent and value of the inheritance of
a person are transmitted through his death to another or others by
his will or by operation of law.