125.051 Ralla v. Ralla Pascual

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UNIVERSITY OF THE PHILIPPINES COLLEGE OF LAW Criminal Law 2

Martin Alfonso Pascual D2025 Niel Anthony Borja

Case Name Ralla v. Ralla

Topic Real Parties-in-Interest

Case No. | Date G.R. No. 78646. July 23, 1991

Ponente Cruz
Pedro and Pablo are brothers. Pedro was disinherited by his father, and instead the
father sold a part of his property to Pablo. Pedro questioned the validity of the sale. SC
Case Summary
said that Pedro has no standing due to his disinheritance, therefore he is not a real
party-in-interest.
The real party-in-interest is the party who stands to be benefited or injured by the
judgment or the party entitled to the avails of the suit. "Interest" within the meaning of
Doctrine the rule means material interest, an interest in issue and to be affected by the decree,
as distinguished from mere interest in the question involved, or a mere incidental
interest.

RELEVANT FACTS
1. Pedro and Pablo Ralla are brothers. Their father is Rosendo Ralla.
2. Rosendo executed a will while he was still alive, disinheriting Pedro and leaving everything he owned to
Pablo, to who he said he had earlier sold a part of his property for P10k.
3. In the intestate proceedings, Pedro’s disinheritance was disapproved by the trial court..
a. the CA reversed the disapproval, and the MR was denied with finality.
b. The grounds for disinheritance was met after finding that the requisites of a valid disinheritance
was complied with in the will (Pedro threatened to kill his father, who was afraid of his and had
earlier sued him for slander and grave oral defamation)
4. Pedro filed a complaint to annul the transaction between Rosendo and Pablo on the ground that it was
simulated.
5. Trial court declared the sale null and void
6. Resolution of the MR reversed the decision and held the sale to be valid.
7. CA reinstated the trial court’s original decision

ISSUE RATIO
No.

As a general rule, one having no right or interest to protect cannot invoke the
Whether the decision of jurisdiction of the court as a party-plaintiff in an action.
the trial court declaring
the sale null and void is In this case, the decision of the court in the disinheritance of Pedro has long since
correct become final. Since then, Pedro Ralla no longer had the legal standing to
question the validity of the sale executed by Rosendo in favor of his other son
Pablo.

RULING
WHEREFORE, the decision of the respondent court dated January 23, 1987, is
set aside and another judgment is hereby rendered dismissing Civil Case 194
(originally Civil Case 4624) in the Regional Trial Court of Ligao, Albay, Branch 5.
SO ORDERED.
Narvasa, Gancayco, Griño-Aquino and Medialdea, JJ ., concur.

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