G.R. No. 175057 - Santos-Concio vs. Department of Justice

On May 5, 1980, Philippine National Railways (PNR) accepted Gaudencio Romualdez's offer to purchase scrap/unserviceable rails located in Del Carmen and Lubao, Pampanga, for a total of ₱96,600.00.
Romualdez paid the purchase price and, on May 26, 1980, sent a letter to Atty. Cipriano Dizon, PNR’s Acting Purchasing Agent, authorizing Lizette R. Wijanco (later Angeles), his representative, to withdraw the awarded scrap rails.
Lizette Wijanco-Angeles was the petitioner’s wife.

On the same day, Lizette requested PNR to transfer the location of withdrawal to Murcia, Capas, and San Miguel, Tarlac, since the original locations were not ready.
PNR granted the request but later suspended the withdrawal due to alleged documentary discrepancies and pilferage of PNR scrap properties worth over ₱500,000.00.

The Angeles spouses demanded a refund of ₱96,000.00 from PNR.
PNR refused, claiming that 54.658 metric tons of scrap rails worth ₱114,781.80 had already been withdrawn by Lizette under a delivery receipt.
On August 10, 1988, the Angeles spouses filed suit for specific performance and damages against PNR and its corporate secretary, Rodolfo Flores, praying for delivery of 46 metric tons of scrap rails and payment of damages and attorney’s fees.
Lizette later died and was substituted by her heirs, including her husband, the petitioner Laureno T. Angeles.

On April 16, 1996, the Regional Trial Court (RTC) dismissed the complaint for lack of cause of action, holding that Lizette was only Romualdez’s authorized representative in withdrawing the rails, not an assignee of his rights.
The Court of Appeals (CA) affirmed the dismissal in its June 4, 2001 decision and denied the petitioner’s motion for reconsideration in its September 17, 2001 resolution.

The petitioner filed a Rule 45 petition assailing the CA's decision and resolution, claiming the CA erred in ruling that petitioner and his wife were not the real parties-in-interest.

Whether Lizette R. Wijanco-Angeles was Romualdez’s assignee or merely his authorized representative (agent) for the withdrawal of the scrap rails.
Whether the petitioner and his spouse had legal standing (real party-in-interest) to sue for specific performance and damages against PNR.
Whether the May 26, 1980 letter from Romualdez constituted a power of attorney or assignment of rights.