Case Digest (G.R. No. 150128)
Case Digest (G.R. No. 150128)
Facts:
Laureano T. Angeles v. Philippine National Railways (PNR) and Rodolfo Flores, G.R. No. 150128, August 31, 2006, Supreme Court Second Division, Garcia, J., writing for the Court.On May 5, 1980, PNR accepted an offer by Gaudencio Romualdez to buy scrap/unserviceable rails located in Del Carmen and Lubao, Pampanga, for a total purchase price of P96,600.00. Romualdez paid the stated purchase price and, by letter dated May 26, 1980 addressed to Atty. Cipriano Dizon (PNR Acting Purchasing Agent), "authorized" Lizette R. Wijanco (later Lizette W. Angeles) to be his "lawful representative in the withdrawal of the scrap/unserviceable rails" and stated he gave her the original award and official receipt and "waiver of rights, interests and participation in favor of LIZETTE R. WIJANCO."
That same day Lizette sought and obtained PNR's permission to change the withdrawal locations to sites in Tarlac. PNR later suspended withdrawals because of alleged documentary discrepancies and reported pilferages of PNR scrap properties. The spouses Angeles (Lizette and petitioner Laureano T. Angeles) demanded refund of the purchase price; PNR refused, asserting that a delivery receipt signed by Lizette showed withdrawal of 54.658 metric tons of rails worth more than the payment claimed.
On August 10, 1988 the spouses Angeles filed suit for specific performance and damages in the Regional Trial Court (RTC) of Quezon City, Branch 79, praying that PNR be directed to deliver 46 metric tons of scrap rails and to pay damages and attorney’s fees. After issues were joined and trial conducted, Lizette died and was substituted by her heirs, including petitioner Laureano Angeles. On April 16, 1996, the RTC dismissed the complaint for lack of cause of action, holding that Lizette was merely Romualdez’s representative in withdrawal and not an assignee of his rights; hence the plaintiffs were not real parties-in-interest.
Petitioner appealed to the Court of Appeals (CA), which in a Decision dated June 4, 2001, affirmed the RTC; the CA denied reconsideration in its Resolution of September 17, 2001. Petitioner then filed a petition for review under Rule 45 before the Supreme Court, which is the subject of this decision.
Issues:
- Are petitioner Laureano T. Angeles and his late wife Lizette W. Angeles the real parties-in-interest with standing to sue against PNR?
- Did Romualdez’s May 26, 1980 letter effect an assignment of his rights in the awarded scrap rails to Lizette, or did it merely constitute authority for her to act as his representative/agent?
- Was the May 26, 1980 letter sufficient to constitute a valid power of attorney despite not being in any particular form or notarized?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)