G.R. No. 181186 - Siguion Reyna Montecillo and Ongsiako Law Offices vs. Chionlo-Sia

The primary issue is whether a law firm, acting as counsel for a party in intestate proceedings, can file a petition for certiorari to protect its own interests.
The petitioner, Siguion Reyna Montecillo & Ongsiako Law Offices (SRMO), represented Remedios N. Rodriguez in intestate proceedings regarding the estate of her deceased husband, Susano J. Rodriguez.

Remedios initiated intestate proceedings for her husband's estate, which was filed as Sp. Proc. No. 4440 in the Regional Trial Court (RTC) of Lucena City.
The RTC denied her request for a widow's allowance, which was later reversed by the Court of Appeals (CA), granting her a monthly allowance of P3,000.00.
Remedios executed a Deed of Sale of Inheritance, selling her rights in the estate to Remigio M. Gerardo, and authorized him to receive payments related to the estate.

After the CA's decision on the widow's allowance became final, SRMO filed a motion for payment of the allowance, which the estate subsequently paid.
In 2002, Remedios filed a motion questioning the RTC's approval of the estate partition and demanded the return of the allowance received by SRMO.
The RTC ordered SRMO to reimburse the estate, leading SRMO to argue that it was merely enforcing a judgment for its client.

The RTC denied SRMO's motion to be excused from reimbursement, stating that the sale of inheritance was not disclosed and that the widow's allowance is personal in nature.
SRMO elevated the case to the CA, which dismissed the petition on the grounds that SRMO lacked standing as it was not a party in the original proceedings.

SRMO contended that it was an "aggrieved party" entitled to file a petition for certiorari, claiming a violation of its right to due process.
The Estate argued that SRMO had no standing as it was not the real party in interest and had acted solely as counsel for Remedios and Gerardo.

The Court clarified that the term "aggrieved party" in Rule 65 refers to those who were parties in the original proceedings.
The Court emphasized that allowing any person feeling injured to file for certiorari would lead to excessive litigation and burden the courts.

The Court noted that the RTC's order for reimbursement was directed at SRMO in its personal capacity, which is atypical as such orders are usually addressed to the parties involved.
SRMO's role was limited to facilitating the transfer of funds to Gerardo, and it did not claim the funds for its own benefit.

Under agency law, an agent is not personally liable for the principal's obligations unless they exceed their authority or bind themselves personally.
The Court found that SRMO acted within its authority and did not bind itself to Gerardo's obligations.

The RTC's justification for ordering SRMO to reimburse was based on its failure to report the transfer of interest, which the Court found unjustified.
The Rules of Court do not require counsel to report such transfers, and the action could continue in the name of the original party unless directed otherwise by the court.

The Court recognized that while the general rule limits certiorari to parties in the original proceedings, exceptions exist.
SRMO's direct interest in challenging the RTC's order was acknowledged, as it was being required to reimburse funds already accounted for to its client.

The Court discussed the definition of a real party in interest, emph...continue reading