G.R. No. 181186 February 3, 2016
SIGUION REYNA MONTECILLO AND ONGSIAKO LAW OFFICES, Petitioner, vs. HON. NORMA CHIONLO-SIA, in her Capacity as Presiding Judge of Branch 56 of the Regional Trial Court of Lucena City, and the TESTATE ESTATE OF DECEASED SUSANO RODRIGUEZ, Represented by the Special Administratrix, Respondents.

FACTS

Petitioner SRMO Law Firm acted as counsel for Remedios Rodriguez in intestate proceedings for her deceased husband’s estate. The Court of Appeals granted Remedios a widow’s allowance. Subsequently, Remedios sold all her rights and interests in the estate to Remigio Gerardo via a Deed of Sale and executed a Special Power of Attorney authorizing Gerardo to receive any property due to her. Gerardo later substituted SRMO as his attorney-in-fact. After the CA decision became final, SRMO, representing Gerardo, moved for and received the accrued widow’s allowance from the estate.
Years later, the RTC, acting motu proprio, ordered SRMO to reimburse the estate for the widow’s allowance it had received. The RTC reasoned that the sale of inheritance was not made known to it and that a widow’s allowance is personal and cannot be sold. SRMO filed a petition for certiorari with the Court of Appeals, which dismissed it on the ground that SRMO lacked legal standing as it was not a party to the proceedings below but merely counsel.

ISSUE

Whether the petitioner law firm, SRMO, has the legal standing to file a petition for certiorari to challenge the RTC order directing it to reimburse the widow’s allowance.

RULING

Yes, SRMO has legal standing to file the petition. The Supreme Court clarified that the requirement for a “person aggrieved” under Rule 65 of the Rules of Court is not confined to parties of record in the lower court. A person is considered aggrieved when a judgment or order adversely affects their legal rights. The RTC’s Order of August 21, 2003, directly commanded SRMO to reimburse a substantial sum of money. This order imposed a clear personal legal obligation on the law firm, distinct from its role as an agent or counsel. While SRMO received the funds as an agent for Gerardo, the reimbursement order was issued against SRMO itself, making it a real party-in-interest in the certiorari proceeding to challenge that specific directive. The Court held that the CA erred in dismissing the petition purely on the basis of lack of standing, as the order sought to be annulled directly prejudiced SRMO by commanding it to perform a specific act involving its own potential liability. The case was remanded to the CA to resolve the petition on its merits.