SECTION 1.

Who may be parties; plaintiff and defendant

Roxas vs. Galindo
G.R. No. L-13578 | May 31, 1960
Facts:
The heirs of Roxas filed a complaint regarding Lot No. 1048, claiming that the
defendants failed to execute a final deed of sale despite prior agreements.
The defendants moved to dismiss, arguing that the plaintiffs lacked valid
representation and that the case was barred by res judicata. The trial court
dismissed the case against one of the defendants, Federico de Guzman, due
to lack of valid representation but allowed the case to continue against the
other defendants.
Subsequently, the plaintiffs sought to amend their complaint to include new
allegations regarding ratification and adverse possession. The defendants
opposed this amendment, claiming that the dismissal was final and
constituted res judicata. The trial court denied the amendment, ruling that
the dismissal was an adjudication on the merits.
Issue Relevant to Rule 3, Section 1:
Whether the plaintiffs, as heirs of Roxas, had the legal capacity to sue and
whether the defendants had valid standing as parties under Rule 3, Section 1
of the Rules of Court.
Ruling:
The Supreme Court ruled that only natural or juridical persons, or entities
authorized by law, may be parties in a civil action. The Court emphasized
that:
 1. The plaintiffs, as heirs of Roxas, had to establish their legal standing to
sue by proving that they were authorized to represent the estate or
had a legal interest in the disputed land.
2. A party cannot sue or be sued unless they are a natural person,
juridical entity, or an entity authorized by law. If a party lacks legal
personality, any complaint against them may be dismissed, as was the
case with Federico de Guzman.
3. If a party lacks proper representation, their participation in a case may
be challenged through a motion to dismiss on the ground of lack of
legal capacity to sue or be sued.
4. An amended complaint must comply with the rules on proper parties,
meaning the plaintiffs must demonstrate that they are the rightful
parties-in-interest and that the defendants are properly named.
Doctrine:
• Under Rule 3, Section 1, only those who have legal capacity—either as
natural persons, juridical persons, or authorized entities—may be
plaintiffs or defendants in a civil action.
• A case may be dismissed if a party lacks the proper legal personality to
sue or be sued.
Disposition:
The Supreme Court upheld the trial court’s ruling, affirming that the
dismissal against one defendant was proper due to lack of valid
representation. However, it clarified that amendments to pleadings should
be allowed when necessary to prevent multiplicity of suits, provided that the
parties involved have the proper legal standing.
 SEC. 2. Parties in interest
Public Interest Center, Inc. v. National Power Corporation
(G.R. No. 125509)
Facts: Petitioners Public Interest Center, Inc., Laureano T. Angeles, and
Jocelyn P. Celestino filed a complaint before the Regional Trial Court (RTC) of
Quezon City, challenging the validity of contracts related to the Bataan
Nuclear Power Plant (BNPP). These contracts were between the National
Power Corporation (NPC) and Westinghouse Electric S.A., later assigned to
Westinghouse International Projects Company (WIPCO). The petitioners
argued that the contracts and related agreements were null and void.
The Republic of the Philippines took ownership of the BNPP in 1986 through
Executive Orders issued by President Corazon Aquino. Disputes arose,
leading to a 1995 settlement agreement between the Philippine
government and Westinghouse.
The petitioners, claiming standing as taxpayers, sought to nullify the BNPP
contract and its related agreements, requesting a temporary restraining
order (TRO) and preliminary injunction to prevent their implementation.
Procedural History:
• The Republic and NPC moved to dismiss the amended complaint,
arguing lack of legal capacity to sue, lack of cause of action, and
forum shopping.
• WIPCO also moved to dismiss, citing statute of limitations and similar
grounds.
• The RTC dismissed the complaint, ruling that the petitioners lacked
standing and that the case did not present justiciable public interest
issues.
Issues:
1. Whether the petitioners are the real parties in interest in the case.
2. Whether the petitioners have standing to challenge the contracts.
Ruling: The Supreme Court upheld the RTC’s dismissal, emphasizing the
principle that a real party in interest is one who stands to benefit or suffer
injury from the judgment of the case. Unless otherwise authorized by law,
every action must be prosecuted or defended in the name of the real party
in interest.
1. Real Party in Interest:
o The Court ruled that the petitioners were not real parties in
interest because they were neither directly benefited nor
injured by the contracts.
o The BNPP contract was between the government and private
entities, and the petitioners had no personal stake in its
implementation beyond their status as taxpayers.
2. Lack of Direct Injury:
o While taxpayers may sue to prevent illegal expenditures of
public funds, they must show substantial interest and direct
injury.
o The petitioners failed to prove that the contracts directly
harmed them, making their standing insufficient.
Doctrine Applied:
• A real party in interest is the one who stands to benefit or be injured
by the outcome of the case.
• Taxpayer suits require a clear demonstration of illegal use of public
funds.
 • Mere interest in good governance or public policy does not
automatically grant legal standing.
Disposition: The petition was denied, and the RTC’s dismissal was affirmed
for lack of standing and failure to establish a real party in interest.
 Sec. 3 Representatives as parties.
Nuguid Vda. de Haberer v. Court of Appeals
G.R. No. L-42699 to L-42709
Facts:
Florentina Nuguid Vda. de Haberer filed eleven complaints for recovery of
possession of a parcel of land registered in her name. The trial court
dismissed these complaints, leading her to file an appeal.
During the appeal process, Nuguid passed away. Her counsel notified the
court and requested either:
1. Suspension of the period for filing the appellant's brief, or
2. Extension of time to file the brief.
However, the appellate court only acted on the third motion, ultimately
denying the extension and dismissing the appeal due to the failure to file
the brief within the required time. A motion for reconsideration was also
denied.
Issue:
Whether the appellate court erred in dismissing the appeal without
ordering the substitution of the deceased party by her legal representatives.
Ruling:
The Supreme Court reversed the appellate court’s dismissal and emphasized
that:
1. Under Rule 3, Section 3 and Section 17, when a party dies, the court
must order the legal representative or heirs to appear within a
specified period.
 2. The failure to order substitution before dismissing the appeal
rendered the proceedings void.
3. The attorney-client relationship does not automatically end upon a
party’s death in cases affecting property rights.
4. The court must exercise judicial discretion in applying procedural
rules, prioritizing substantive justice over technicalities.
Doctrine Applied (Rule 3, Section 3):
• A representative may sue or be sued on behalf of a real party in
interest (e.g., an heir or executor).
• The legal representative must be substituted in the case after the
original party’s death.
• Failure to properly substitute parties renders a judgment void, as the
case lacks jurisdiction over the proper parties.
Disposition:
The Supreme Court reinstated the appeal, ruling that the appellate court
erred by dismissing the case without proper substitution. The case was
remanded for further proceedings with the legal representatives of the
deceased party.
 SEC. 4. Spouses as parties
Sps. Zapanta v. Rustan Commercial Corporation (G.R. No. 248063)
Facts:
Nilda Eleria Zapanta, employed as Credit & Collection Manager at Rustan
Commercial Corporation (RCC), was responsible for overseeing credit
transactions. An audit in 2001 uncovered irregularities, revealing that Nilda
ordered P600,000 worth of gift certificates under a fictitious account (Rita
Pascual) and sold them at discounted rates to third parties. Following an
investigation, RCC demanded an explanation from Nilda, but instead, she
submitted a retirement letter.
RCC filed a collection suit for damages against Nilda and her husband,
German V. Zapanta, leading to the issuance of a writ of preliminary
attachment by the Regional Trial Court (RTC).
Procedural History:
1. RTC Ruling – The court ruled in favor of RCC, holding Nilda liable for
P78,120,000 in actual damages, plus legal costs and attorney's fees.
2. Court of Appeals (CA) Decision – Affirmed the RTC ruling, rejecting
Sps. Zapanta's due process claims and confirming their liability.
3. Petition for Review on Certiorari (Supreme Court) – Sps. Zapanta
questioned the due process of the proceedings and whether RCC had
a valid cause of action against them.
Issues:
1. Were Sps. Zapanta denied due process?
2. Did RCC have a valid cause of action against them?
3. Was German Zapanta properly included in the case as Nilda’s
spouse?
Ruling:
The Supreme Court denied the petition and upheld the CA’s ruling:
1. No Violation of Due Process – Sps. Zapanta were given ample
opportunity to defend themselves, but their actions (e.g., repeated
hearing postponements) contributed to delays.
2. Valid Cause of Action – RCC sufficiently alleged fraud and
mismanagement, supporting its claim for collection and damages.
3. Liability of the Husband (Rule 3, Section 4) – The Court affirmed
German Zapanta’s inclusion in the suit, citing:
o Under Rule 3, Section 4 of the Rules of Court, spouses shall sue
or be sued jointly, except when the law provides otherwise.
o The Family Code states that obligations incurred during
marriage, if they benefit the family, are jointly chargeable to
both spouses.
o Since Nilda’s fraudulent activities involved financial dealings
during the marriage, both spouses were held jointly liable.
Doctrine Applied (Rule 3, Section 4):
• Spouses must sue or be sued jointly unless an exception applies.
• Family Code principles dictate that liabilities benefiting the conjugal
partnership apply to both spouses.
• A husband may be included in a collection suit arising from the wife's
financial obligations during marriage.
Disposition:
The Supreme Court denied the petition and affirmed the lower court rulings,
holding Sps. Zapanta liable for damages.
Key Takeaways on Rule 3, Section 4:

✔ Spouses are generally treated as a single legal entity for litigation

purposes.
✔ Financial obligations incurred by one spouse during marriage can be
enforced against both, especially if the family benefited.
✔ Fraudulent acts related to conjugal assets can result in joint liability for
the spouses.
 SEC. 5. Minor or incompetent persons.
Knutson v. Sibal-Knutson (G.R. No. 239215)
Facts:
Randy Michael Knutson, an American citizen, married Rosalina Sibal Knutson
in Singapore. They had a daughter, Rhuby, and moved to the Philippines in
2011. Due to Rosalina’s extramarital affairs and gambling addiction, the
couple became estranged.
Rosalina allegedly neglected and abused Rhuby, creating a harmful
environment. Randy sought police assistance, but they could not intervene
in domestic matters. Consequently, he filed a petition for protection and
custody orders under RA 9262 (Anti-Violence Against Women and Their
Children Act of 2004) before the Regional Trial Court (RTC).
Issue:
Can a father file a petition under RA 9262 for protection and custody orders
on behalf of his minor child against the mother?
Ruling:
The Supreme Court granted Randy’s petition, ruling that:
• RA 9262 applies to mothers as offenders if they commit violence
against their children.
• The law’s language does not limit protection orders to fathers as
perpetrators, and its intent is to protect both women and children
from domestic violence.
• Randy, as Rhuby’s father, has the legal standing to seek protection for
his minor child under RA 9262.
Doctrine (Rule 3, Section 5, Rules of Court - Minor or Incompetent
Persons):
A minor may sue or be sued with the assistance of a parent, guardian, or
guardian ad litem. In this case:
• Rhuby, being a minor, could not file the petition herself.
• Randy, as her natural guardian, had the right to sue on her behalf to
secure protection and custody orders.
• The RTC erred in dismissing the petition, as RA 9262 does not preclude
fathers from seeking protection orders on behalf of their children.
Key Takeaway:
A minor child must be represented by a parent or guardian in legal
proceedings. The Supreme Court reinforced a father’s right to seek legal
remedies for his child’s protection, even against the child’s mother, when
domestic violence is involved.
 SEC. 6. Permissive joinder of parties
Pantranco North Express, Inc. v. Standard Insurance Co., et al.
G.R. No. 140746,March 16, 2005
Facts:
A Pantranco bus collided with a jeepney, causing damage and injuries. As a
result:
• Standard Insurance Company, as the insurer of the jeepney, paid for
the damages and sought reimbursement.
• Martina Gicale, a passenger, claimed damages for her injuries.
• Both parties filed a joint complaint against Pantranco in the Regional
Trial Court (RTC) for their respective claims.
Pantranco challenged the joinder of parties, arguing that their claims should
have been filed separately.
Issue:
Was the joinder of Standard Insurance and Martina Gicale as plaintiffs in
the same complaint proper under the rules on permissive joinder of
parties?
Ruling:
The Supreme Court upheld the joinder of parties, stating that:
1. Same Transaction Rule – The claims arose from the same incident
(the bus-jeepney collision), satisfying the first requirement for
permissive joinder.
2. Common Question of Law or Fact – The central issue was whether
Pantranco’s negligence caused the accident, which is common to both
plaintiffs.
 3. Judicial Efficiency – The joinder prevented a multiplicity of suits and
facilitated judicial economy by allowing a single case to resolve all
related claims.
4. Jurisdictional Amount – The totality rule applied, and since the
combined claims exceeded the jurisdictional threshold, the RTC had
jurisdiction over the case.
Doctrine:
Under Rule 3, Section 6 of the Rules of Civil Procedure, permissive joinder
of parties is proper when:
• The right to relief arises from the same transaction or series of
transactions.
• There is a common question of law or fact affecting all parties.
• The joinder does not violate jurisdiction and venue rules.
Since both claims arose from one collision and involved the same evidence,
their joinder was valid to promote efficiency and avoid duplicative litigation.
 SEC. 7. Compulsory joinder of indispensable parties.
Plasabas v. Court of Appeals
G.R. No. 166519 | March 31, 2009
Facts:
Petitioners Nieves Plasabas and Marcos Malazarte filed a complaint for
recovery of title over a parcel of coconut land in Canturing, Maasin,
Southern Leyte against respondents Dominador Lumen and Aurora Aunzo.
The land was registered under Tax Declaration No. 3587 in the name of
petitioner Nieves.
Respondents contested ownership, claiming that the land was inherited
from their common ancestor, Francisco Plasabas. Evidence showed that the
land was co-owned by Nieves and her siblings, making them indispensable
parties to the case.
The trial court dismissed the case for failure to implead the co-owners,
ruling that the absence of indispensable parties rendered any judgment
ineffective. The Court of Appeals affirmed this dismissal.
Issue:
Was the dismissal of the case for non-joinder of indispensable parties
proper?
Ruling:
The Supreme Court reversed the dismissal and remanded the case for a
decision on the merits. It ruled that:
1. Co-ownership Exception – Under Article 487 of the Civil Code, a co-
owner can file an action for recovery of property without joining all
co-owners.
 2. Indispensable Parties Not Required – Since the action was for the
benefit of all co-owners, the failure to implead them did not warrant
dismissal.
3. Error in Applying Rule 3, Section 7 – While the rule mandates joinder
of indispensable parties, it does not apply when a co-owner sues for
recovery of property on behalf of all co-owners.
Doctrine:
• Article 487 of the Civil Code allows a co-owner to file an action
without joining other co-owners, as such an action benefits all of
them.
• Compulsory joinder of indispensable parties under Rule 3, Section 7
is not absolute, especially in cases involving co-ownership.
Disposition:
The case was remanded to the trial court for resolution on the merits.
 SEC. 8. Necessary party.
Heirs of Manzano v. Kinsonic Philippines, Inc.
G.R. No. 214087 | February 27, 2023
Facts:
The Heirs of Spouses Manzano entered into a Contract to Sell a parcel of
land in Bulacan with Kinsonic Philippines, Inc. The purchase price was
P23,026,900.00, and Kinsonic made partial payments totaling
P8,000,000.00. However, the petitioners later refused further payments,
arguing that the contract was automatically rescinded due to non-payment
within the agreed period.
Kinsonic filed a complaint for specific performance, and the trial court ruled
in its favor, ordering the execution of the deed of sale or the return of
payments made. The Court of Appeals (CA) upheld this ruling, modifying it
only by removing exemplary damages.
On appeal, the petitioners raised the issue of non-joinder, arguing that the
administrator of the estates/conjugal partnership should have been
included as a necessary or indispensable party to the case.
Issue:
• Whether the administrator of the estates/conjugal partnership is an
indispensable or necessary party under Rule 3, Section 8 of the Rules
of Court.
Ruling:
The Supreme Court ruled that the administrator is not an indispensable
party, as no such administrator had been appointed. Instead, the Court
classified the administrator as a necessary party, whose non-joinder did not
render the proceedings void.
 1. Distinction Between Indispensable and Necessary Parties
o Indispensable Party: A party without whom no final
determination can be made in an action. Their absence deprives
the court of jurisdiction over the case.
o Necessary Party: A party whose presence is desirable for a
complete determination of the case but is not essential for
jurisdiction. The case may proceed without them.
2. Application to the Case
o Since no administrator was appointed, the estate’s interests
were already represented by the heirs, making the
administrator's presence non-essential.
o The non-joinder of a necessary party does not warrant the
dismissal of a case but only requires the court to order the
party’s inclusion if necessary.
3. Effect of Raising the Issue on Appeal
o The petitioners were barred from raising new arguments at this
stage. Courts do not allow litigants to raise new issues for the
first time on appeal, especially if they had the opportunity to do
so earlier.
Doctrine:
• The absence of an indispensable party renders proceedings null and
void, but the absence of a necessary party does not affect jurisdiction.
• Heirs may represent the estate in legal proceedings if no
administrator has been appointed.
• New issues cannot be raised for the first time on appeal unless there
are exceptional circumstances.
Disposition:
The Supreme Court affirmed the Court of Appeals’ ruling, holding that the
non-joinder of the estate administrator was immaterial to the resolution of
the case.
 SEC. 9. Non-joinder of necessary parties to be pleaded.
Carandang v. Heirs of De Guzman
G.R. No. 160347 | November 29, 2006
Facts:
Arcadio and Maria Luisa Carandang were stockholders and corporate officers
of Mabuhay Broadcasting System (MBS). They subscribed to an increase in
capital stock, which Quirino de Guzman allegedly paid on their behalf,
amounting to P336,375.00. When the Carandangs refused to reimburse him,
de Guzman filed a complaint to recover the amount.
The Regional Trial Court (RTC) ruled in favor of de Guzman, ordering the
Carandang spouses to pay the amount, plus interest and attorney's fees.
The Court of Appeals (CA) upheld this decision. The Carandangs then
appealed to the Supreme Court, arguing that de Guzman's wife, Milagros de
Guzman, should have been joined as a necessary party under Section 9,
Rule 3 of the Rules of Court.
Issue:
• Whether the case should be dismissed for non-joinder of Milagros de
Guzman as a necessary party.
Ruling:
The Supreme Court rejected the argument that Milagros de Guzman was a
necessary party under Section 9, Rule 3 of the Rules of Court.
1. Non-Joinder of a Necessary Party Does Not Dismiss the Case
o The rule states that if a necessary party is not joined, the pleader
must explain their omission.
o If the court finds the omission unjustified, it may order the
party's inclusion, but the case is not automatically dismissed.
 o The absence of a necessary party does not affect jurisdiction
over the case.
2. Milagros de Guzman Was Not Indispensable
o The absence of an indispensable party would make the
proceedings void, but this does not apply to a necessary party.
o Since Quirino de Guzman was the real party in interest in
recovering the amount, his wife’s inclusion was not essential to
the case.
o As no prejudice was caused, the court proceeded properly
without Milagros.
3. Effect of Non-Joinder
o The Carandangs failed to raise this issue earlier, and the
Supreme Court noted that new issues cannot be raised for the
first time on appeal.
o Even if Milagros were a necessary party, her absence would not
justify dismissing the case.
Doctrine:
• Non-joinder of a necessary party does not dismiss the case; the court
may order inclusion if needed.
• Indispensable parties are required for jurisdiction; necessary parties
are not.
• New issues cannot be raised for the first time on appeal.
Disposition:
The Supreme Court affirmed the CA’s decision, rejecting the non-joinder
argument and upholding the order for the Carandangs to pay P336,375.00.
 SEC. 10. Unwilling co-plaintiff.
East West Banking Corp. v. Cruz
G.R. No. 221641 | July 12, 2021
Facts:
East West Banking Corporation (the Bank) filed a Complaint for Sum of
Money with a Writ of Preliminary Attachment against Ian Cruz and Paul
Chua Hua. The Bank alleged that Paul, a sales officer, fraudulently
transferred funds from Francisco and Alvin Cruz’s accounts to Ian’s account.
Ian then used the funds to secure a loan, which he later repaid. When
Francisco and Alvin demanded the return of their money, the Bank denied
liability but conducted an audit.
The Regional Trial Court (RTC) initially granted the writ of attachment but
later dismissed the Complaint, ruling that:
1. The Bank failed to state a cause of action as it did not assert any right
of its own.
2. The real parties-in-interest were Francisco and Alvin Cruz, not the
Bank.
3. Including Francisco and Alvin as unwilling co-plaintiffs did not cure the
defect in the Complaint.
The Court of Appeals (CA) dismissed the Bank’s appeal, ruling that it
pursued the wrong mode of review (Rule 41 instead of Rule 45). The Bank
then filed a Petition for Review on Certiorari before the Supreme Court.
Issue:
• Whether the RTC properly dismissed the Complaint despite the Bank's
inclusion of Francisco and Alvin Cruz as unwilling co-plaintiffs under
Section 10, Rule 3 of the Rules of Court.
Ruling:
The Supreme Court affirmed the dismissal of the Complaint, holding that:
1. Section 10, Rule 3 (Unwilling Co-Plaintiff) Did Not Cure the
Complaint's Defects
o The rule allows a plaintiff to include a necessary party as a
defendant if they refuse to join as a plaintiff.
o However, this does not automatically establish a cause of action
if the plaintiff itself lacks legal standing.
o Since the Bank was not the real party-in-interest, its case was
defective regardless of whether Francisco and Alvin were
included.
2. Francisco and Alvin Were the True Real Parties-in-Interest
o The Bank had no direct claim over the misappropriated funds.
o The proper plaintiffs should have been Francisco and Alvin, as
they suffered the direct injury from the fraudulent transactions.
o A plaintiff cannot sue on behalf of another party unless legally
authorized (e.g., by assignment or subrogation).
3. Legal Personality and Cause of Action
o The cause of action must arise from the plaintiff’s own legal
rights, not someone else’s.
o The Bank’s attempt to recover money on behalf of Francisco and
Alvin was improper because they did not assign their rights to
the Bank.
o Thus, the RTC was correct in dismissing the case for lack of a
valid cause of action.
Doctrine:
• An unwilling co-plaintiff (Sec. 10, Rule 3) may be joined as a
defendant, but this does not cure a defective cause of action.
• A party cannot sue on behalf of another unless it has a legal right to
do so.
• Failure to state a cause of action is a ground for dismissal, even if
unwilling co-plaintiffs are included.
Disposition:
The Supreme Court affirmed the CA's ruling, dismissing the Bank's case for
lack of a cause of action.
 SEC. 11. Misjoinder and non-joinder of parties
Boston Equity Resources, Inc. v. Court of Appeals
G.R. No. 173946 | June 19, 2013
Facts:
Boston Equity Resources, Inc. filed a Complaint for Sum of Money against
spouses Manuel and Lolita Toledo on December 24, 1997. During the
proceedings, Lolita revealed that her husband, Manuel, had already passed
away on July 13, 1995—before the complaint was even filed. The petitioner
sought to identify Manuel's heirs and filed a Motion for Substitution, which
the trial court granted on October 9, 2000.
The trial continued until October 7, 2004, when Lolita filed a Motion to
Dismiss, arguing that:
1. The trial court lacked jurisdiction over Manuel since he was already
deceased when the case was initiated.
2. The estate of Manuel should have been included as an indispensable
party in the complaint.
The trial court denied the motion to dismiss, stating it was filed out of time
and that Lolita was already barred by estoppel by laches for failing to raise
the issue earlier.
Lolita filed a Petition for Certiorari with the Court of Appeals (CA), which
ruled in her favor. The CA held that:
• The trial court committed grave abuse of discretion in not dismissing
the case.
• The estate of Manuel was an indispensable party and should have
been included.
Boston Equity then elevated the case to the Supreme Court via Petition for
Review on Certiorari.
Issue:
• Whether the non-joinder of the estate of Manuel Toledo warranted
the dismissal of the case under Section 11, Rule 3 of the Rules of
Court.
Ruling:
The Supreme Court reversed the CA’s decision, ruling that:
1. Non-joinder of parties is not a ground for dismissal
o Under Section 11, Rule 3, neither misjoinder nor non-joinder of
parties is a valid ground for dismissing a case.
o The trial court had the discretion to order the inclusion of
necessary parties, but failing to do so does not warrant
automatic dismissal.
2. The Estate of Manuel was NOT an Indispensable Party
o The obligation in question was solidary between Manuel and
Lolita.
o Article 1216 of the Civil Code allows the creditor to proceed
against any solidary debtor.
o Since Lolita was a solidary co-debtor, the Bank could validly sue
her without including the estate of Manuel.
3. Trial Court Did Not Commit Grave Abuse of Discretion
o The motion to dismiss was filed late, after years of litigation
and presentation of evidence.
 o The issue of jurisdiction over Manuel should have been raised
much earlier.
o Lolita was already estopped from questioning jurisdiction at such
a late stage.
Doctrine:
• Misjoinder or non-joinder of parties is not a ground for dismissal
(Sec. 11, Rule 3).
• A solidary debtor can be sued separately, without including the other
co-debtors or their estate (Art. 1216, Civil Code).
• A party cannot raise jurisdictional issues too late in the proceedings if
they failed to object earlier (estoppel by laches).
Disposition:
The Supreme Court granted the petition and reversed the CA’s ruling,
effectively allowing the case against Lolita Toledo to proceed.
 SEC. 12. Class suit
Capitol Medical Center, Inc. v. Court of Appeals
G.R. No. 82499 | October 13, 1989
Facts:
Capitol Medical Center College (CMCC), operated by Capitol Medical Center,
Inc. (CMCI), was an educational institution offering nursing and medical-
related courses. Due to faculty disputes over benefits, students and teachers
staged protests that disrupted school operations. As tensions escalated, the
CMCI Board of Directors decided to close the school at the end of the first
semester of the 1987–1988 academic year.
A group of students and parents filed a class suit, claiming that the closure
violated their contractual right to education. The Regional Trial Court (RTC)
issued a writ of preliminary mandatory injunction, ordering CMCC to
reopen. The Court of Appeals (CA) upheld this decision, reasoning that
students had a binding contract with the school to continue operations until
they completed their courses.
CMCI elevated the case to the Supreme Court, arguing that the lower courts
erred in compelling the reopening of the school.
Issue (Relevant to Class Suit):
• Did the students properly file a class suit under Rule 3, Section 12 of
the Rules of Court?
Ruling:
The Supreme Court ruled that the class suit was improper and reversed the
lower court’s decisions. It held that:
1. Lack of Common or General Interest
 o A class suit requires that the subject matter affects all members
in a similar manner.
o While many students were affected, their individual
circumstances varied, such as tuition payments, academic
standing, and transfer opportunities.
o The Supreme Court ruled that the case was not one of common
or general interest for all students, as their rights and interests
were not identical.
2. Failure to Show Adequate Representation
o A class suit requires that those filing the case are sufficiently
representative of the whole class.
o The Court found no evidence that the plaintiffs adequately
represented all affected students, particularly those who did
not join the lawsuit.
3. No Clear Legal Right to Demand Reopening
o The Supreme Court held that the students had no vested right
to demand the school’s continued operation beyond the
semester for which they had enrolled.
o The contract between students and CMCC was only for the
duration of each semester.
Doctrine:
• A class suit requires a common or general interest among numerous
parties; individual circumstances must not vary significantly.
• Representation in a class suit must be sufficiently numerous and
representative to protect the interests of all concerned.
Disposition:
The Supreme Court annulled the injunction, ruling that the closure of the
school was justified and that the class suit was not proper under Rule 3,
Section 12 of the Rules of Court.
 SEC. 13. Alternative defendants
The American Insurance Company v. Macondray & Co., Inc., Republic of the
Philippines, and Bureau of Customs
G.R. No. L-24031, August 19, 1967
Facts:
The American Insurance Company filed a complaint against Macondray &
Co., Inc. and the Bureau of Customs as alternative defendants for the
recovery of a sum of money arising from the loss and non-delivery of goods
consigned to an importer. The Bureau of Customs argued that it lacked the
capacity to be sued and moved for the dismissal of the case. The plaintiff
amended the complaint to include the Republic of the Philippines as a
defendant.
The lower court dismissed the case against the Republic of the Philippines
and the Bureau of Customs, ruling that it had no jurisdiction over them. The
plaintiff appealed, arguing that it properly joined alternative defendants
under Section 13, Rule 3 of the Rules of Court, as it was uncertain who was
liable for the loss.
Issue:
Whether the joinder of alternative defendants was proper under Section
13, Rule 3 of the Rules of Court, considering that one of the defendants (the
Republic of the Philippines) cannot be sued without its consent.
Ruling:
The Supreme Court held that while joinder of alternative defendants is
allowed when there is uncertainty regarding liability, the doctrine of state
immunity still applies. The Republic of the Philippines cannot be sued
without its consent, and the Bureau of Customs, being a government
agency, also cannot be sued separately from the State.
Thus, the complaint against the Republic and the Bureau of Customs was
properly dismissed. However, the joinder of alternative defendants was
valid under Section 13, as the plaintiff was unsure who was responsible for
the loss.
Doctrine Applied:
• Section 13, Rule 3 of the Rules of Court: A plaintiff may join
alternative defendants if uncertain about who is liable.
• State Immunity Doctrine: The government cannot be sued without its
consent.
Disposition:
The Supreme Court dismissed the complaint against the Republic of the
Philippines and the Bureau of Customs due to state immunity.
 SEC. 14. Unknown identity or name of defendant.
Santos, Jr. vs. PNOC Exploration Corp.
G.R. No. 170943 | September 23, 2008
Facts:
PNOC Exploration Corporation filed a complaint for sum of money against
Pedro T. Santos, Jr. to recover an unpaid car loan amounting to
P698,502.10. The trial court attempted to personally serve summons, but it
was unsuccessful due to the defendant’s unknown whereabouts.
Consequently, PNOC requested service of summons by publication, which
the court granted.
Since Santos, Jr. failed to file an answer, the trial court allowed PNOC to
present evidence ex parte, leading to a judgment against the defendant.
Later, Santos, Jr. moved for reconsideration, arguing improper service of
summons, but the trial court denied his motion. The Court of Appeals
affirmed the trial court’s ruling.
Issue:
Whether the service of summons by publication was valid under Section 14,
Rule 3 of the Rules of Court, which allows a defendant to be sued under an
unknown designation when their identity or name is unknown.
Ruling:
The Supreme Court upheld the validity of the service of summons by
publication, emphasizing that:
• Service by publication is allowed when a defendant's whereabouts
are unknown, even in a personal action like this case.
 • The Rules of Court permit suing an unknown defendant under an
alternative designation until their true identity is discovered, requiring
an amendment to the pleading once identified.
• The petitioner was properly notified through publication, and his
failure to file an answer justified the ex parte proceedings.
Doctrine Applied:
• Section 14, Rule 3 of the Rules of Court: When the identity or name of
a defendant is unknown, they may be sued under an alternative
designation. Once identified, the pleading must be amended
accordingly.
• Service of Summons by Publication: Allowed when personal service is
unsuccessful due to the defendant’s unknown whereabouts, even in
personal actions.
Disposition:
The petition was denied, and the lower court’s decision was affirmed. The
Supreme Court ruled that the service of summons by publication was
proper, and there was no abuse of discretion in the trial court’s
proceedings.
 SEC. 15. Entity without juridical personality as defendant.
Association of Flood Victims and Jaime Aguilar Hernandez, Petitioners,
vs.
Commission on Elections, Alay Buhay Community Development
Foundation, Inc., and Weslie Ting Gatchalian, Respondents.
G.R. No. 203775 | August 5, 2014

Facts:
The petitioners, Association of Flood Victims and Jaime Aguilar Hernandez,
filed a Petition for Certiorari and/or Mandamus under Rule 65 of the Rules
of Court, challenging COMELEC Minute Resolution No. 12-0859. The said
resolution confirmed the re-computation of party-list seat allocations in the
House of Representatives for the 2010 elections, proclaimed Alay Buhay
Community Development Foundation, Inc. (Alay Buhay) as a winning party-
list group, and declared Weslie T. Gatchalian as its representative.
The petitioners argued that COMELEC committed grave abuse of discretion
in issuing the resolution and sought a writ of mandamus to compel its
publication.
Ruling:
The Supreme Court dismissed the petition on the ground that the
petitioners lacked legal capacity to sue.
• Association of Flood Victims was still in the process of incorporation
and had no juridical personality to sue.
• An unincorporated association, such as the petitioner, cannot file a
case in its own name unless expressly allowed by law.
 • Under Rule 3, Sections 1 and 2 of the Rules of Civil Procedure, only
natural or juridical persons or entities authorized by law may be
parties in a civil action.
• Jaime Aguilar Hernandez, who filed the case as the association's lead
convenor, failed to show that he was authorized to represent its
members.
• Petitioners also lacked locus standi as they failed to establish any
direct or personal injury from the issuance of the COMELEC
resolution.
The Court cited Sec. 15, Rule 3 of the Rules of Court, which allows entities
without juridical personality to be sued under their commonly known
name, but this does not extend to their capacity to file suits unless
otherwise authorized by law.
Doctrine:
• Unincorporated associations cannot sue in their own name unless
expressly authorized by law.
• Sec. 15, Rule 3 of the Rules of Court applies only when such an entity
is sued, but does not grant it the capacity to file suits.
• A party must have juridical personality or be a real party in interest
to initiate a case.
Disposition:
Petition dismissed.
 SEC 16. Death of party; duty of counsel
Sumaljag v. Spouses Literato and Rodrigo
G.R. No. 149787 | June 18, 2008
Facts:
Josefa D. Maglasang filed a complaint before the Regional Trial Court (RTC)
to nullify a deed of sale over a parcel of land allegedly executed between her
and the Spouses Diosdidit and Menendez Literato. The respondents denied
the claim and filed a counterclaim, arguing that petitioner Judge Antonio
Sumaljag and Josefa occupied the disputed land without their authority.
During the pendency of the case, Josefa died on May 3, 1999. Her counsel,
Atty. Zenen Puray, filed a notice of death and substitution beyond the 30-day
period required under Section 16, Rule 3 of the Rules of Court. He moved
for Sumaljag to be substituted in place of Josefa, alleging that she had
previously transferred her rights to him through a quitclaim deed. However,
respondent Menendez objected, arguing that Josefa should be substituted
by her full-blood sister, Michaeles Maglasang Rodrigo.
The RTC denied Atty. Puray’s motion for substitution and instead ordered
Michaeles Rodrigo to represent the deceased. The CA upheld the RTC’s
ruling. Petitioner Sumaljag elevated the case to the Supreme Court, arguing
that the lower courts erred in ordering the substitution of Josefa with her
heir instead of him, a transferee pendente lite.
Issue:
Whether the Court of Appeals erred in dismissing the petition based on the
application of Section 16, Rule 3 of the Rules of Court regarding substitution
of parties upon the death of a litigant.
Ruling:
The Supreme Court denied the petition, affirming the rulings of the RTC and
CA. It ruled that:
1. Duty of Counsel to Report Death Timely – Under Section 16, Rule 3, a
deceased party’s counsel must report their death within 30 days and
provide the name and address of their legal representative(s). Failure
to do so may result in disciplinary action. Atty. Puray filed the notice
beyond the prescribed period, though the court granted an extension.
2. Heirs as Proper Substitutes – The primary rule in case of a party’s
death is substitution by legal heirs. The rule allows substitution
without requiring the appointment of an executor or administrator. In
this case, the RTC correctly ordered Michaeles Rodrigo, a legal heir, to
substitute for Josefa instead of Sumaljag, as the rule prioritizes heirs
over transferees.
3. Transferee Pendente Lite Not Automatically a Substitute – Sumaljag’s
claim that he should be substituted as Josefa’s successor in interest
was incorrect. Section 16, Rule 3 applies only to heirs or legal
representatives and does not automatically recognize a transferee
pendente lite as a substitute for a deceased litigant. If a party acquires
interest in the subject matter during litigation, their rights are
governed under Section 20, Rule 3, but this does not override the
primary rule of substitution by heirs.
4. Compliance with Procedural Rules Ensures Due Process – The
purpose of Section 16, Rule 3 is to ensure due process by allowing
proper representation for deceased parties. The RTC correctly applied
this rule by designating an heir to continue Josefa’s claims.
Doctrine:
• Upon the death of a litigant, their counsel must inform the court
within 30 days and provide the legal representative’s name and
address.
• The legal heirs are the proper substitutes unless an executor or
administrator is appointed.
• A transferee pendente lite is not automatically substituted in place of
the deceased litigant.
Disposition:
Petition denied. The Court upheld the RTC and CA rulings that substituted
Josefa’s heir, Michaeles Rodrigo, instead of Judge Sumaljag.
 SEC. 17. Death or separation of a party who is a public officer.
Del Rosario vs. Shaikh
G.R. No. 206249 | December 10, 2019 | Supreme Court
Facts:
This case involves a dispute over the election of the Liga ng mga Barangay
(Liga) President for the Municipality of Bagac. Eva T. Shaikh was elected as
Liga President, making her an ex-officio member of the Sangguniang Bayan.
However, her status was contested due to an alleged failure of elections.
Despite this, she attended council sessions and later filed a petition for
mandamus to compel the release of her salaries and emoluments, which
had been withheld by then-Mayor Rommel V. Del Rosario.
The Regional Trial Court (RTC) dismissed Shaikh’s petition, ruling that no
valid election had taken place. However, the Court of Appeals (CA) reversed
the decision, holding that Shaikh was at least a de facto officer and thus
entitled to compensation. The CA ruled that municipal officials had a
ministerial duty to release her salaries.
Del Rosario then filed a Petition for Review on Certiorari before the Supreme
Court, arguing that he was not legally mandated to release Shaikh’s salaries
and that such authority belonged to the Vice-Mayor.
Issue Relevant to Rule 3, Section 17:
Whether substitution of a public officer is proper under Rule 3, Section 17 of
the Rules of Court.
Ruling:
The Supreme Court addressed the procedural issue concerning the
substitution of public officers. Under Rule 3, Section 17, when a public
officer who is a party in an official capacity ceases to hold office during the
pendency of a case, the action may be continued by or against the successor,
provided there is a substantial need to maintain the action and that the
successor adopts or continues the predecessor’s actions. The court must be
satisfied of these conditions before substitution is made.
In this case, Mayor Del Rosario had ceased to hold office during the
proceedings. However, the Supreme Court ruled that substitution was not
automatic. The new Mayor could only be substituted if there was a
demonstrated need to continue the case against the office, and if the
successor either continued or threatened to continue the predecessor’s acts.
The Court emphasized that substitution requires a showing that the
successor is legally responsible for the contested act, which was not
established here.
Doctrine:
Substitution of a public officer under Rule 3, Section 17 is not automatic. It
requires (1) proof of substantial need to continue the case, and (2) evidence
that the successor is adopting or continuing the predecessor’s actions.
Disposition:
The Supreme Court ruled that Mayor Del Rosario was not the proper official
to release the salaries, as this duty belonged to the Vice-Mayor.
Consequently, the petition was granted, and the CA’s ruling was reversed.
 SEC. 18. Incompetency or incapacity
Caniza vs. Court of Appeals
G.R. No. 110427 | February 24, 1997 | Supreme Court
Facts:
Carmen Ca Iza, a 94-year-old woman, was declared incompetent due to her
advanced age and health issues. As a result, her niece, Amparo Evangelista,
was appointed as her legal guardian with full authority to manage her
estate.
The guardian subsequently filed an ejectment suit against the Estradas, who
had been living in Ca Iza's house rent-free. The complaint alleged that the
Estradas were unlawfully withholding possession of the property despite
demands to vacate. The tenants, however, claimed that they were allowed
to stay due to family ties and that Ca Iza had made a will bequeathing the
property to them.
The Regional Trial Court (RTC) ruled in favor of the guardian, ordering the
Estradas to vacate the property. The Court of Appeals (CA) affirmed the
decision, recognizing the guardian’s authority to recover possession on
behalf of the incompetent ward. The Estradas then appealed to the Supreme
Court (SC), arguing that they had a valid right to stay based on an
unprobated will.
Issue Relevant to Rule 3, Section 18:
Whether the ejectment action could continue despite Ca Iza's incompetency
and subsequent death under Rule 3, Section 18 of the Rules of Court.
Ruling:
The Supreme Court upheld the rulings of the lower courts, emphasizing the
guardian’s legal authority to act on behalf of the incompetent ward. Under
Rule 3, Section 18, if a party becomes incompetent, the case may continue
with the assistance of a legal guardian or guardian ad litem. The Court ruled
that:
1. Authority of a Guardian: A legally appointed guardian has the right to
manage the ward's estate, including the power to recover possession
of property through legal action.
2. Continuation of Proceedings: The action properly continued with the
guardian representing Ca Iza in court. The Estradas’ claim based on an
unprobated will was invalid, as a will has no legal effect until admitted
to probate.
3. Effect of Death on the Case: Although the relationship between
guardian and ward ends upon the ward’s death, the ejectment case
survived because heirs can be substituted in ongoing legal
proceedings. Evangelista, as an heir, was substituted for Ca Iza in the
appeal, allowing the ejectment action to continue.
Doctrine:
• Rule 3, Section 18 allows a case to proceed when a party becomes
incompetent, provided they are represented by a legal guardian or
guardian ad litem.
• An ejectment action survives the death of the incompetent party,
allowing heirs to continue the proceedings.
Disposition:
The Supreme Court ruled in favor of Amparo Evangelista and upheld the
ejectment order against the Estradas.
 SEC. 19. Transfer of interest
Levi Strauss & Co. vs. Sevilla
G.R. No. 219744 | March 1, 2021 | Supreme Court
Facts:
Levi Strauss & Co., the owner of the well-known "LEVI'S" trademark, filed a
petition for the cancellation of the "LIVE'S" trademark registered by Antonio
Sevilla. Sevilla later transferred the trademark rights to Antonio L. Guevarra,
who subsequently assigned them to Dale Sy. Levi Strauss argued that
"LIVE'S" was confusingly similar to "LEVI'S" and was likely to cause consumer
confusion.
The Intellectual Property Office (IPO) and the Court of Appeals (CA) ruled
against Levi Strauss, dismissing the case on the grounds of mootness due to
the trademark’s transfer and res judicata based on a prior case. Levi Strauss
elevated the case to the Supreme Court (SC).
Issue Relevant to Rule 3, Section 19:
Whether the transfer of interest in the "LIVE'S" trademark affected the
continuation of the case under Rule 3, Section 19 of the Rules of Court.
Ruling:
The Supreme Court ruled that the case was not moot despite the transfer of
the trademark. Applying Rule 3, Section 19, the Court held that:
1. An action may continue despite the transfer of interest. The original
party remains bound by the outcome, unless the court orders the
substitution or joinder of the transferee.
2. The transferee (Dale Sy) was bound by the result of the case. A mere
transfer of interest does not extinguish an ongoing legal dispute over
the validity of the trademark.
 3. Mootness did not apply. Since the trademark registration remained
valid and subsisting, the issue of its cancellation was still justiciable.
Ultimately, the Supreme Court ruled in favor of Levi Strauss, reversed the
CA’s decision, and ordered the cancellation of the "LIVE'S" trademark,
emphasizing that trademark rights do not automatically transfer free from
ongoing legal challenges.
Doctrine:
• Under Rule 3, Section 19, a case does not automatically become
moot due to the transfer of interest. The original party remains in the
case unless the court orders the transferee’s substitution or joinder.
• Trademark disputes involving cancellation petitions survive a transfer
of ownership, and transferees are bound by the outcome.
Disposition:
The Supreme Court granted the petition, reversed the Court of Appeals'
ruling, and ordered the cancellation of the "LIVE'S" trademark registration.
 SEC. 20. Action on contractual money claims
Survivors of Agrichemicals in Gensan, Inc. vs. Standard Fruit Co.
G.R. No. 206005 | April 12, 2023 | Supreme Court
Facts:
The case involves a contractual money claim for damages filed by the
Survivors of Agrichemicals in Gensan, Inc. (SAGING) against several foreign
corporations, including Standard Fruit Company and Dole Food Company.
The plaintiffs alleged that they suffered health problems due to exposure to
dibromochloropropane (DBCP), a chemical used in banana plantations.
During the pendency of the case, some defendants passed away before the
final judgment was rendered. The issue arose as to whether the claims
should continue against the estate of the deceased defendants under Rule
3, Section 20 of the Rules of Court.
Issue Relevant to Rule 3, Section 20:
Whether the death of a defendant in an action for recovery of money arising
from a contract abates the case or allows it to continue under Rule 3,
Section 20.
Ruling:
The Supreme Court ruled that the case should continue despite the death
of some defendants. Applying Rule 3, Section 20, the Court held that:
1. An action for the recovery of money arising from a contract does not
abate upon the defendant’s death. The case remains pending and
shall continue until final judgment.
2. The judgment obtained by the plaintiffs shall be enforced against the
estate of the deceased defendant. This ensures that valid contractual
money claims are not extinguished by death.
 3. The trial court must allow substitution of parties so that the proper
representatives of the deceased defendants can defend the case and
ensure that any monetary judgment is properly adjudicated against
the estate.
Thus, the Supreme Court revived the case, rejecting arguments that it had
become moot due to the death of certain defendants. The ruling ensures
that contractual claims remain enforceable even after the defendant’s
death, protecting the rights of plaintiffs seeking recovery.
Doctrine:
• Under Rule 3, Section 20, an action for recovery of money based on a
contract does not abate upon the death of a defendant. Instead, the
case continues, and any favorable judgment for the plaintiff shall be
enforced against the estate of the deceased.
• Substitution of parties is required, ensuring that the estate remains
liable for contractual obligations incurred by the deceased before their
passing.
Disposition:
The Supreme Court revived the case, allowing it to proceed against the
estate of the deceased defendants in accordance with Rule 3, Section 20.
 SEC. 21. Indigent party
Spouses Algura vs. Local Government Unit of the City of Naga
G.R. No. 150135 | October 30, 2006 | Supreme Court
Facts:
Spouses Antonio F. Algura and Lorencita S.J. Algura filed a complaint against
the Local Government Unit (LGU) of Naga City for damages due to the
alleged illegal demolition of their property. Simultaneously, they filed a
motion to litigate as indigent litigants, claiming financial incapacity to pay
court fees.
The Regional Trial Court (RTC) initially granted their motion, exempting
them from paying filing fees. However, upon re-evaluation, the RTC later
disqualified them based on their income and property assessments, ruling
that they did not meet the indigency threshold.
Issue Relevant to Rule 3, Section 21:
Whether the trial court erred in disqualifying the Spouses Algura from
indigent status, thereby denying them exemption from payment of docket
and other legal fees.
Ruling:
The Supreme Court ruled in favor of the Spouses Algura, holding that the
trial court erred in its strict interpretation of the indigency rules. The Court
emphasized:
1. Access to justice must be ensured for all, regardless of financial
status. The Constitution guarantees equal protection under the law,
and poverty should not bar individuals from seeking legal redress.
2. Indigency should not be determined solely by fixed income
thresholds but also by a holistic assessment of the litigant's actual
 financial condition, including necessary living expenses. The Alguras'
low net income and financial burden after demolition should have
been properly considered.
3. A proper hearing is required before denying indigent status. The trial
court should have thoroughly examined whether the petitioners had
sufficient resources for their basic needs before revoking their
exemption.
4. Indigent litigants are entitled to exemption from payment of docket
and other fees, as well as transcripts of stenographic notes, unless the
court finds them financially capable after due hearing.
Doctrine:
• Rule 3, Section 21 of the Rules of Court protects the right of indigent
litigants to pursue legal action without financial hindrance. Courts
must assess their financial capacity holistically, considering basic
needs and not just income figures.
• Denial of indigent status requires a proper hearing, and adverse
parties may challenge indigency claims before final judgment. If later
found financially capable, the litigant must pay court fees, or
execution may issue.
Disposition:
The Supreme Court reinstated the Spouses Algura's indigent status,
exempting them from paying court fees and allowing them to proceed with
their case without financial burden.
 SEC 22. Notice to the Solicitor General.
Gonzales vs. Chavez
G.R. No. 97351 | February 4, 1992 | Supreme Court
Facts:
Petitioner Gonzales filed a case questioning the Solicitor General’s
withdrawal from representing the government in certain cases, alleging that
this led to the unauthorized hiring of private lawyers and misuse of public
funds. The issue revolved around the Solicitor General’s duty to represent
the government and whether private legal representation was valid in cases
involving public interest.
Issue Relevant to Rule 3, Section 22:
Whether the Solicitor General’s appearance is required in cases involving
the validity of a treaty, law, ordinance, executive order, presidential decree,
or regulations, as per Section 22, Rule 3 of the Rules of Court.
Ruling:
The Supreme Court ruled that the Solicitor General has a critical role in
representing the government and ensuring that laws are properly defended
in court. The Court emphasized that:
1. The Solicitor General is the principal law officer of the government
and has the duty to represent its interests in legal proceedings,
especially in cases questioning the validity of laws, ordinances, or
executive acts.
2. Courts may require the appearance of the Solicitor General in their
discretion when a case involves the validity of any law, regulation, or
executive order, ensuring that the government's position is properly
defended.
 3. The Solicitor General cannot arbitrarily withdraw representation
without just cause. In cases affecting public interest, the Solicitor
General must appear either personally or through a duly designated
representative.
4. The unauthorized hiring of private lawyers to represent government
agencies in cases where the Solicitor General should appear is
impermissible, unless explicitly allowed by law.
Doctrine:
• Rule 3, Section 22 grants the court discretion to require the Solicitor
General's appearance in cases challenging laws or executive actions,
ensuring that legal matters affecting public interest are properly
defended.
• The Solicitor General cannot refuse representation without a valid
reason, particularly in cases involving the legality of government acts.
Disposition:
The Supreme Court issued a writ of mandamus, compelling the Solicitor
General to resume representation in the disputed cases and prohibiting
government agencies from hiring private lawyers without legal authority.