Case Summary (G.R. No. 173297)
Petitioner
Stronghold Insurance Company, Inc., domestic insurer and surety issuing Bond No. 68427 JCL No. 02370 in favor of the Cuencas and Tayactac to secure the attachment.
Respondents
Tomas, Marcelina and Milagros Cuenca, and Bramie T. Tayactac—stockholders of Arc Cuisine, Inc.—seeking recovery for the loss and damage of corporate property wrongfully attached.
Key Dates
• January 19, 1998 – Complaint and attachment application filed by Marañon.
• February 11, 1998 – Surety bond posted.
• February 13, 1998 – Writ of preliminary attachment issued.
• April 28, 2003 – RTC awards P1,000,000 bond plus damages, moral and exemplary damages, and attorney’s fees against Marañon and Stronghold, jointly and solidarily.
• January 31, 2006 – CA affirms RTC decision.
• March 6, 2013 – Supreme Court decision reversing CA.
Applicable Law
Under the 1987 Constitution, Article VIII, Section 1, judicial power extends only to actual controversies. Rule 3, Section 2 of the Rules of Court requires that every action be prosecuted in the name of the real party in interest. The Corporation Code establishes that a corporation has a personality separate from its stockholders.
Facts and Procedural History
Marañon secured a writ of attachment against Arc Cuisine, Inc. properties and posted a P1,000,000 surety bond with Stronghold Insurance. The sheriff levied corporate equipment and later lost custody of the items. The Cuencas and Tayactac successfully petitioned the CA to dismiss the attachment for lack of RTC jurisdiction, then sought damages below. The RTC held Marañon and Stronghold liable; the CA affirmed.
Issue on Appeal
Whether the stockholders, in their individual capacity, were real parties in interest entitled to enforce the surety bond for damages arising from the wrongful attachment of corporate assets.
Legal Framework on Real Party in Interest
A real party in interest must have a present, substantial right to the relief sought, not a mere expectancy or derivative interest. Only the entity whose legal rights were invaded may prosecute a claim. Stockholders’ rights to corporate property are indirect and insufficient to establish standing for personal recovery.
Court’s Analysis and Application
Arc Cuisine, Inc. alone owned the attached assets; respondents’ stockholdings conferred an aliquot interest in corporate equity, not title to specific property. Precedents (Asset Priv
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Facts
- Manuel D. Marañon, Jr. filed Civil Case No. 98-023 on January 19, 1998 in the Regional Trial Court (RTC) of Parañaque City against the Cuencas for collection of money and damages, seeking a writ of preliminary attachment.
- The RTC granted the attachment on January 26, 1998, conditioned upon a ₱1,000,000 bond. Marañon later impleaded Bramie Tayactac as co-defendant.
- On February 11, 1998, Marañon posted a surety bond (SICI Bond No. 68427 JCL (4) No. 02370) for ₱1,000,000 with Stronghold Insurance Company, Inc.
- The sheriff levied on various personal properties of Arc Cuisine, Inc. (leased commissary/office) on February 16–17, 1998; those properties belonged to the corporation, not to the individual respondents.
- The respondents (Cuencas and Tayactac) moved to dismiss and quash the writ, arguing intra-corporate matters belonged to the SEC, but the RTC denied and the CA ultimately annulled the RTC orders for lack of jurisdiction and remanded the case for determination of damages.
- The levied properties were found missing from the warehouse recommended by Marañon; rumors placed them at a pastry shop owned by Marañon.
- On April 6, 2000, the respondents moved to require delivery of the attached properties and to hold Stronghold Insurance and Marañon liable for damages, moral and exemplary damages, and attorney’s fees.
- The RTC, after trial, on April 28, 2003, held Marañon and Stronghold Insurance jointly and solidarily liable for ₱1,000,000 (bond amount), ₱100,000 moral damages, ₱50,000 exemplary damages, ₱100,00