GR 150128; (August, 2006) (Digest)
G.R. No. 150128 August 31, 2006
LAUREANO T. ANGELES, Petitioner, vs. PHILIPPINE NATIONAL RAILWAYS (PNR) AND RODOLFO FLORES, Respondents.
FACTS
On May 5, 1980, the Philippine National Railways (PNR) accepted Gaudencio Romualdez’s offer to purchase scrap rails. After Romualdez paid, he sent a letter dated May 26, 1980, to PNR’s Acting Purchasing Agent, authorizing “LIZETTE R. WIJANCO” (petitioner’s late wife, Lizette Wijanco-Angeles) as his “lawful representative in the withdrawal of the scrap/unserviceable rails awarded to me.” The letter stated he gave her the original award and receipt, which “will indicate my waiver of rights, interests and participation in her favor.”
PNR permitted Lizette to withdraw rails from an alternative location but later suspended operations due to documentary discrepancies and reported pilferage. The spouses Angeles demanded a refund of the purchase price, which PNR refused, contending that rails worth more than the claimed amount had already been withdrawn. The spouses filed a complaint for specific performance and damages.
ISSUE
Whether the petitioner, as the successor-in-interest of Lizette, is the real party-in-interest entitled to sue PNR for specific performance based on the May 26, 1980 letter from Romualdez.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. The pivotal determination was the legal character of Lizette’s authority under Romualdez’s letter. The Court ruled that the letter constituted Lizette as a mere agent, not an assignee of Romualdez’s contractual rights. The letter explicitly authorized her only as a “lawful representative in the withdrawal” of the rails. The subsequent phrase stating that the documents “will indicate my waiver of rights…in favor of LIZETTE” did not effect a present assignment but was at best an indication of a future intent. The document was construed strictly as a power of attorney, granting only the specified power to withdraw.
Consequently, as a mere agent, Lizette had no independent right to enforce the contract against PNR. The real party-in-interest remained the principal, Romualdez. Since a contract may generally be violated only by or against a contracting party, an agent without assignment of rights cannot sue in their own name. The petitioner’s claim that Lizette paid PNR was dismissed as an afterthought, inconsistent with prior judicial admissions. Therefore, the petitioner lacked a cause of action.