G.R. No. 97463 June 26, 1992
JESUS M. IBONILLA, DOLORES R. GAPAS, WILFRED BATERINA, AZUCENA TABLANTE, ERNESTO SANTIAGO, ENRIQUE AUZA, INOCENCIO BUOT, JR., GENE PASAJE, RODOLFO SAN GABRIEL, JUANITA ABELLANOSA, CAROLINA BONIEL, EPPE CRISPO, ILDEFONSO TINAPAY, LUCIA OMPAD, CATALINA SICAD, ABRAHAM BARRIOQUINTO, ANTONIO ELISER, ALBERTO TAGALOG, LEONARDA ESPINA, LUCILE GIMARINO, ROMEO PINATEL, HERNAN ESTABILLA, LEO PELLETERO, BENITO PALER, JERICO BOLAMBAO, NOEL CAMORO, REYNALDO VILLAROSA, RAMIL MANAYON, JOSELITO MILAY, MANUEL LABITAD, THERESA TINAPAY, CATHERINE MARTTN, SUSAN ROLLAN, CRISELDA CANA, MARIFE CEBALLOS, JANICE ALBINO, ROLANDO S. TABUNA, ANTONIO ALISER, MA. PAULETTE C. LEDRES, MIRA COLITA, MODESTO CORTES, HERNAN ESTAVILLA, JOANN ESPINA, SEVERINO LEBUMFACIL, ROBERTO REGALADO, KELLY AYUDA, MARINO OCHEA, CARMELITA ARANCO, VICTORIA TOMARONG, LOLITA MALAGAR, WILLY REPOLLO, ANABELLA TRUZ, ARLENE DONAN, GEOVANI ROMARATE, MACARIO GUARIN, JULIUS POLAYAPOY, WILSON BORDADORA, DARWIN LLESOL, and BONIFACIO ILLUSTRISIMO, petitioners,

vs.
PROVINCE OF CEBU, CEBU STATE COLLEGE OF SCIENCE & TECHNOLOGY (College of Agriculture) formerly Sudlon Agricultural School/Cebu (Sudlon) Agricultural School, its BOARD OF TRUSTEES and/or members namely, DR. LOURDES QUISUMBING, DR. ATANASCIO ELMA, DR FRANCISCO B. CONCILLO, MR. TOMAS RAMOS and HON. EMILIO M.R. OSMEÑA., ALQUIN VILLAHERMOSA and the COURT OF APPEALS, Manila, respondents.

FACTS

In 1952, the use and usufruct of 40 parcels of land was granted to the Cebu (Sudlon) Agricultural School. On March 18, 1960, the Province of Cebu donated the lots to the school, subject to conditions that ownership would revert to the province if the school ceased to operate and that the properties could not be alienated, leased, or encumbered. Pursuant to BP Blg. 412, the school became an extension of the Cebu State College of Agriculture in 1983. On November 18, 1988, the Province of Cebu demanded the return of the donated lots, claiming the donation was void ab initio as the school lacked the personality to be a donee of real property. The petitioners, comprising officials, faculty, employees, parents of students, and various school organizations of the Cebu (Sudlon) Agricultural School, opposed the rescission and filed an action to quiet title. The Province of Cebu alleged the deed was null and void and, as the school had ceased to exist, the lots should be reconveyed. On March 10, 1989, the Province filed a motion to dismiss, stating the action had become moot due to a Memorandum of Agreement dated February 1, 1989, between the Province and the Cebu State College of Science and Technology (CSCST), allocating 19 lots to the Province, 23 lots to the school, and reserving one lot for a government center. This agreement was ratified by the Sangguniang Panlalawigan and the school’s Board of Trustees. The petitioners refused to withdraw their suit.

ISSUE

Whether the petitioners are real parties in interest with the legal standing to file an action for quieting of title over the subject parcels of land.

RULING

No. The Supreme Court denied the petition for review, affirming the decisions of the lower courts. The Court held that the petitioners are not real parties in interest. They are not the owners of the lots in question and do not claim any legal interest in them that was violated, nor have they suffered any injury warranting relief. Only a real party in interest, defined as one who would be benefited or injured by the judgment or entitled to the avails of the suit, is allowed to prosecute an action. The Court found that the execution and ratification of the Memorandum of Agreement between the Province and the school’s Board of Trustees resolved the controversy over the donated lots. Therefore, the petitioners lacked the requisite legal standing to maintain the suit for quieting of title.