Case Summary (G.R. No. 186305)
Background Facts
In June and September 1998, V-Gent purchased twenty-six round-trip Manila–Europe tickets from Morning Star. Of these, fifteen were returned unused: Morning Star refunded only six tickets (US$3,445.62) and refused to refund the remaining nine valued at US$5,301.88 despite repeated demands.
Procedural History
· December 15, 2000: V-Gent filed a money claim in the Metropolitan Trial Court (MeTC) for US$5,301.88 plus attorney’s fees.
· January 27, 2006: MeTC dismissed the complaint for lack of cause of action, finding V-Gent failed to prove its claim. Although it noted V-Gent acted as agent of the passengers, it concluded the evidence was insufficient.
· September 25, 2006: On appeal, the Regional Trial Court (RTC) reversed and ordered Morning Star to pay for the nine unrefunded tickets plus attorney’s fees.
· November 11, 2008: The Court of Appeals (CA) granted Morning Star’s petition for certiorari, dismissed V-Gent’s complaint, and held that V-Gent lacked standing as the real party-in-interest.
· February 5, 2009: CA denied reconsideration.
· July 22, 2015: Supreme Court decision denying V-Gent’s petition for certiorari.
Applicable Law
· 1987 Constitution: Ensures access to courts and due process under Article III, Section 1 and Section 14.
· Rule 3, Section 3, Rules of Court: Governs representative suits and the exception allowing an agent to sue in own name for an undisclosed principal, provided the contract does not involve principal’s property.
· Civil Code, Article 1883: Agent acting in own name binds itself when principal is undisclosed and contract does not involve principal’s property.
· Civil Code, Article 1878(15): Distinguishes general acts of administration (collecting payments) from acts of strict dominion (instituting suit), requiring special authority for the latter.
Issue: Real Party-in-Interest (Legal Standing)
V-Gent contends it had standing because:
- The MeTC already recognized it as real party-in-interest and Morning Star did not appeal that finding.
- It acted as principal purchaser and Morning Star refunded payments to it.
- Morning Star is estopped from denying standing after partial refund.
Morning Star maintains:
- No obligation existed to appeal a favorable MeTC dismissal.
- The MeTC never definitively held V-Gent was real party-in-interest.
- The true parties are the ticketed passengers.
- No admissions by Morning Star estop it from contesting standing.
Analysis of Agent’s Capacity under Rule 3, Section 3
Rule 3, Section 3 allows an agent to sue in own name for an undisclosed principal only if:
- The agent acted in its own name;
- The principal was undisclosed;
- The contract does not involve principal’s property.
Here, while V-Gent’s purchase orders and receipts bore its name (element 1), it disclosed the passengers as principals (element 2) and the tickets were paid with the passengers’ funds (element 3). Thus, the exception does not apply and the passengers remain the real parties-in-interest.
Application of Civil Code Provisions
Under Article 1883, an agent acting in own name binds itself provided the principal is undisclosed and the contract does not involve principal’s property. Because V-Gent disclosed the passengers and used their money, it cannot rely on Article 1883. Article 1878(15) further distingui
...continue readingCase Syllabus (G.R. No. 186305)
Facts and Antecedents
- In June and September 1998, petitioner V-Gent, Inc. purchased twenty-six round-trip (Manila–Europe–Manila) plane tickets from respondent Morning Star Travel and Tours, Inc.
- On June 24 and September 28, 1998, V-Gent returned fifteen unused tickets, with a total face value of US$8,747.50.
- Morning Star refunded only six of those tickets, amounting to US$3,445.62, and declined to refund the remaining nine despite repeated demands.
- The unrefunded balance amounted to US$5,301.88.
Procedural History
- December 15, 2000: V-Gent filed a money claim in the Metropolitan Trial Court (MeTC) of Manila (Civil Case No. 169296-CV) for the unrefunded US$5,301.88 plus attorney’s fees.
- Morning Star countered, asserting (a) the tickets were sold under a “buy one, take one” promo (only 14 unused tickets existed, 7 of which were refundable, 6 of which had been refunded already), and (b) V-Gent lacked personality to sue since the real parties in interest were the named passengers.
- January 27, 2006: The MeTC dismissed the complaint for lack of cause of action, finding V-Gent to be agent of the passengers but holding that V-Gent did not prove its entitlement to refund.
- V-Gent appealed to the Regional Trial Court (RTC, Civil Case No. 06-115050).
- September 25, 2006: The RTC reversed the MeTC, ruling that V-Gent had proven its claim and ordering Morning Star to pay for nine unrefunded tickets plus attorney’s fees.
- Morning Star petitioned for certiorari review in the Court of Appeals (CA-G.R. SP No. 97032).
- November 11, 2008: The CA granted the petition, dismissed V-Gent’s complaint, and held that V-Gent was not the real party in interest.
- February 5, 2009: The CA denied V-Gent’s motion for reconsideration.
- V-Gent filed a petition for review on cert