Facts:

The case involves the petitioner, Siguion Reyna Montecillo & Ongsiako Law Offices (SRMO), and the respondents, Hon. Norma Chionlo-Sia, in her capacity as Presiding Judge of Branch 56 of the Regional Trial Court (RTC) of Lucena City, and the Testate Estate of the deceased Susano Rodriguez, represented by the Special Administratrix. The events leading to this case began when Remedios N. Rodriguez, the widow of Susano J. Rodriguez, initiated intestate proceedings for the settlement of her deceased husband's estate, which was docketed as Sp. Proc. No. 4440 in the RTC of Lucena City. During these proceedings, Remedios sought a widow's allowance, which the RTC denied in an order dated August 8, 1983. The Court of Appeals later reversed this decision, granting her a monthly widow's allowance of P3,000.00 effective August 1982.

On February 29, 1988, while the case was still pending, Remedios executed a Deed of Sale of Inheritance, selling all her rights and interes...

Facts:

1. Background of the Case

   • Petitioner Siguion Reyna Montecillo & Ongsiako Law Offices (SRMO) acted as counsel for Remedios N. Rodriguez in the intestate settlement of the estate of her deceased husband, Susano J. Rodriguez, before the Regional Trial Court (RTC) of Lucena City (Sp. Proc. No. 4440).
   • Remedios sought a widow's allowance, which the RTC initially denied but was later granted by the Court of Appeals (CA) at P3,000.00 per month, effective August 1982.

2. Transfer of Rights

   • On February 29, 1988, Remedios executed a Deed of Sale, selling her rights and interests in the estate to Remigio M. Gerardo for P200,000.00.
   • On March 1, 1988, Remedios executed a Special Power of Attorney (SPA) authorizing Gerardo to receive payments on her behalf.
   • Gerardo later designated SRMO as his substitute attorney-in-fact and authorized SRMO to represent him in the proceedings.

3. Payment of Widow's Allowance

   • After the CA's decision became final, SRMO filed a motion for the payment of the widow's allowance, totaling P315,000.00, which the Estate remitted to SRMO in 1991.
   • SRMO claimed it received the amount on behalf of Gerardo, who had purchased Remedios' interests.

4. Dispute Over Reimbursement

   • In 2002, Remedios filed a motion questioning the RTC's approval of the partition and denying the validity of the Deed of Sale. She demanded that SRMO return the widow's allowance.
   • The RTC, in an Order dated August 21, 2003, directed SRMO to reimburse the Estate P315,000.00, reasoning that the widow's allowance was personal and could not be transferred.
   • SRMO argued that it acted as Gerardo's representative and had already accounted for the funds to Gerardo.

5. Proceedings Before the CA

   • SRMO filed a petition for certiorari before the CA, which denied the petition, ruling that SRMO had no standing as it was not a party to the original proceedings.
   • SRMO elevated the case to the Supreme Court, arguing that it was an "aggrieved party" and that the RTC's order violated its right to due process.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Standing to File Certiorari

   • While the general rule under Rule 65 of the Rules of Court limits the remedy of certiorari to parties in the original proceedings, exceptions exist when a non-party is directly affected by the court's order.
   • SRMO, being ordered to reimburse funds it had already accounted for to its client, had a direct and substantial interest in the case, giving it standing to file the petition.

2. Agency Principle

   • Under the law of agency, an agent (SRMO) is not personally liable for the obligations of the principal (Gerardo) unless the agent acts outside the scope of its authority or expressly binds itself to be personally liable.
   • SRMO acted within its authority and did not bind itself personally, making the reimbursement order unjustified.

3. Real Party in Interest

   • A real party in interest is one who stands to be benefited or injured by the judgment. SRMO, being required to return funds it had already transferred to its client, was the real party in interest in challenging the RTC's order.

4. Technical Rules Subordinated to Justice

   • The Court emphasized that technical rules of procedure should not frustrate the cause of justice. Strict application of the rules in this case would result in unjust enrichment of Gerardo at the expense of SRMO.

5. Widow's Allowance

   • The Court did not rule on the transferability of the widow's allowance, as the parties to the Deed of Sale were not impleaded. The issue of enforceability of the Deed of Sale could not be resolved without their participation.

Conclusion:

The Supreme Court ruled in favor of SRMO, holding that it had standing to file the petition for certiorari and that the RTC erred in ordering SRMO to reimburse the widow's allowance. The Court set aside the CA's decision and the RTC's orders, emphasizing that the reimbursement order should have been directed at Gerardo, not SRMO.