Facts:

The case involves Asuncion Abad, the petitioner and appellant, who acted as the attorney-in-fact for Teresa Mendez Villa-Abrille, initiating legal proceedings against Amando Aquino, the respondent and appellee, in the Court of First Instance of Manila. The subject of the suit was the recovery of P 1,700, which represented the balance on a promissory note that Aquino had executed in favor of Villa-Abrille on February 21, 1932. Following the filing of the complaint and subsequent proceedings wherein both parties presented evidence, the Honolulu Iron Works intervened as an appellee. Aquino, in his defense, asserted that the promissory note was linked to a rice mill and motor that he had purchased from the plaintiff. Meanwhile, the Honolulu Iron Works contended that the rice mill had been bought by Mariano Pardo on behalf of the plaintiff from Catton Neill Engineering & Machinery Company, with a note issued to them that had been indorsed to the intervenor. The defendant had also

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Facts:

Background of the Case

• Asuncion Abad, acting as attorney-in-fact for Teresa Mendez Villa-Abrille, filed a suit in the Court of First Instance of Manila against Amando Aquino for the recovery of P1,700.
• The suit was based on a promissory note executed on February 21, 1932 by the defendant in favor of Teresa Mendez Villa-Abrille.

Intervention and Additional Parties

• Honolulu Iron Works was permitted to intervene in the case.
• The intervener’s involvement introduced additional complexities related to the origin of the note and the underlying transaction.

Assertions and Defenses by the Parties

• Defendant’s Defense
• Amando Aquino contended that the note represented the price of a rice mill with its motor sold by the plaintiff.
• Intervener’s Assertion
• Honolulu Iron Works claimed that the rice mill in question had been acquired by Mariano Pardo in the name and on behalf of Asuncion Abad from Catton Neill Engineering & Machinery Company.
• A note in favor of Catton Neill Engineering & Machinery Company, endorsed to the intervener, was issued in connection with the purchase.
• The defendant had guaranteed the payment of the note by mortgaging the machinery, and a balance (P875 plus P175) remained unpaid by both the plaintiff and the defendant.

Procedural History and Results in Lower Courts

• The trial court rendered judgment in favor of the plaintiff for the claim amount of P1,700, with interest at 12% per annum, plus attorney’s fees and costs.
• Both the defendant and the intervener appealed the decision.
• The Court of Appeals dismissed the appeal on the grounds that the action was not initiated by the real party in interest, citing Section 114 of the Code of Civil Procedure, which mandates that every action must be prosecuted in the name of the real party in interest.

Significance of the Power of Attorney Issue

• The promissory note was executed in favor of Teresa Mendez Villa-Abrille, yet the complaint was filed by Asuncion Abad in her capacity as attorney-in-fact.
• The Court of Appeals noted that the power of attorney (Exhibit B), executed by Teresa Mendez Villa-Abrille in favor of Asuncion Abad, did not authorize her to bring an action for the recovery of the note.
• Consequently, the proceedings from the filing of the complaint to the judgment were considered null and void due to the absence of the real party plaintiff.

Issue:

Legal Standing and the Identity of the Real Party in Interest

• Whether an action can be appropriately prosecuted by an attorney-in-fact in lieu of the real party in interest as required by the law.
• The interpretation and application of Section 114 of the Code of Civil Procedure concerning the necessity of naming the real party in interest.

The Possibility of Amending the Complaint

• Whether the complaint could be amended by substituting the name of the real party in interest for that of Asuncion Abad, as suggested by the petitioner based on the doctrine from Alonso vs. Villamor.
• The impact of the intervener’s presence (Honolulu Iron Works) on any such amendment process.

Validity of the Proceedings

• Whether the entire proceedings, including the judgment rendered, are null and void due to the improper filing by an attorney-in-fact rather than the real party in interest.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)