IRON AND STEEL AUTHORITY vs CA & MA. CRISTINA FERTILIZER CORP.

FACTS: The Iron & Steel Authority (ISA) was vested with the power to initiate expropriation
proceedings under PD272. It filed an expropriation proceeding against Maria Cristina Fertilizer
Corporation (MCFC), however during the pendency of the case, ISA's statutory existence expired.
MCFC filed a motion to dismiss arguing only natural or juridical persons or entites authorized by law
could be parties to a civil case, with the trial court granted. ISA moved for reconsideration contending
that its juridical existence continues until the winding up of its affairs could be completed. In the
alternative, ISA urged that the Republic of the Philippines, being the real party-in-interest, should be
allowed to be substituted for ISA.

ISSUE: Whether the Republic is entitled to be substituted for ISA in view of the expiration of ISA's
term

HELD: Yes, it is entitled to be substituted. The ISA appears to be a non-incorporated agency or

instrumentality of the Government of the Republic of the Philippines, and is properly regarded as an
agent or a delegate of the Republic. When the statutory term of a non-incorporated agency expires, the
powers, duties and functions as well as the assets and liabilities of that agency revert back to, and are
re-assumed by, the Republic of the Philippines, in the absence of special provisions of law specifying
some other disposition thereof. Additionally, in the instant case, the ISA instituted the proceedings in its
capacity as an agent, the real party in interest is the Republic.

Instrumentality refers to any agency of the National Government, not integrated within the department
framework, vested with special functions or jurisdiction by law, endowed with some if not all corporate
powers, administering special funds, and enjoying operational autonomy, usually through a charter.