GR 159156; (January, 2005) (Digest)
G.R. No. 159156 ; January 31, 2005
RAMON P. ARON, petitioner, vs. FRANCISCO REALON, DOMINGO REALON and FELIPE REALON, representing the HEIRS OF MARCIANO REALON and ROMAN REALON, EMILIANO R. PURIFICACION, representing the HEIRS OF ALFREDO REALON and ROMAN REALON, respondents.
FACTS
Roman Realon owned two parcels of land. Upon his death, his son Alfredo and the heirs of his deceased son Buenaventura inherited the properties. In 1979, the heirs executed an extrajudicial settlement and subsequently, through a series of contracts culminating in 1985 Deeds of Sale with Mortgage, sold their undivided shares in one lot, Lot No. 1253, to Ramon Aron. The contracts stipulated that the balance of the purchase price was to be paid upon the vendors securing an Original Certificate of Title for the property. The vendors failed to do so.
Aron himself filed an application for original registration of the lot in 1983. The vendors were notified of the hearing. In 1996, the heirs of the vendors filed a complaint for rescission of the contracts and recovery of possession against Aron, alleging his failure to pay the balance of the purchase price. Aron contended that his obligation to pay was contingent on the vendors first securing the title, which they failed to do.
ISSUE
The core issue was whether the respondents, as plaintiffs, had the legal capacity to sue and whether the complaint stated a cause of action, given that they sued in a representative capacity for deceased persons without attaching the required authority.
RULING
The Supreme Court granted Aron’s petition, reversing the lower courts. The legal logic centered on procedural deficiencies fatal to the complaint. The respondents sued as representatives of the heirs of Marciano, Alfredo, and Roman Realon. However, they failed to attach to the complaint any proof of authority to represent these heirs, such as a special power of attorney or a board resolution, as mandated by the Rules of Court. A complaint filed by one claiming to represent another without demonstrating authority is considered to have been filed by one without legal personality to sue, rendering it dismissible for lack of cause of action.
The Court emphasized that the requirement of authority is not a mere technicality but a matter of substantive law, as no one may represent another without proper authorization. This defect was not cured by the subsequent submission of an affidavit during trial, as the verification of a complaint requires the presenter’s authority to be established at the time of filing. Consequently, the complaint was deemed fatally defective from its inception. The Court also noted that a separate final judgment in an unlawful detainer case, which ordered Aron to pay a specific sum to the respondents, had already attained finality, further undermining the current action for rescission based on non-payment.