Uy v.

CA

G.R. No. 120465. September 9, 1999

Facts: William Uy and Rodel Roxas are agents authorized to sell eight parcels of land by the
owners thereof. By virtue of such authority, petitioners offered to sell the lands, located in Tuba,
Tadiangan, Benguet to respondent National Housing Authority (NHA) to be utilized and
developed as a housing project.ch the NHA Board passed Resolution No. 1632 approving the
acquisition of said lands, with an area of 31.8231 hectares, at the cost of P23.867 million,
pursuant to which the parties executed a series of Deeds of Absolute Sale covering the subject
lands. Of the eight parcels of land, however, only five were paid for by the NHA because of the
report 1 it received from the Land Geosciences Bureau of the Department of Environment and
Natural Resources (DENR) that the remaining area is located at an active landslide area and
therefore, not suitable for development into a housing project. NHA passed a resolution
cancelling the sale over the three parcels of land and subsequently offered the amount of P1.225
million to the landowners as daos perjuicios. Uy and Roxas went to the RTC and obtained a
favourable ruling, NHA appealed to the CA and reversed the ruling. It held that since there was
"sufficient justifiable basis" in cancelling the sale, "it saw no reason" for the award of damages.
The Court of Appeals also noted that petitioners were mere attorneys-in-fact and, therefore, not
the real parties-in-interest in the action before the trial court.

Issue: WON Uy and Roxas are the real party in interest in this case. NO

Held: The real party in interest in this case are the owners of the land. Section 2, Rule 3 of the
Rules of Court requires that every action must be prosecuted and defended in the name of the
real party-in-interest. The real party-in-interest is the party who stands to be benefited or injured
by the judgment or the party entitled to the avails of the suit. "Interest," within the meaning of
the rule, means material interest, an interest in the issue and to be affected by the decree, as
distinguished from mere interest in the question involved, or a mere incidental interest. 6 Cases
construing the real party-in-interest provision can be more easily understood if it is borne in
mind that the true meaning of real party-in-interest may be summarized as follows: An action
shall be prosecuted in the name of the party who, by the substantive law, has the right sought to
be enforced.
Mapalo v. Mapalo

G.R. No. L-21489 and L-21628 May 19, 1966

Facts: Magpalo and Quiba are simple illiterate farmers who are the registered owners of a
residential land in Manaoag, Pangasinan. Magpalo decided to donate the eastern half of his land
to Maximo. However, Magpalo and Quiba were deceived into signing a deed of absolute sale of
the entire land. The document showed a consideration of P500 but Magpalo contended that he
was not able to receive anything. Magpalo built a fence to segregate the donated land. Maximo
registered the deed of sale in his favor and was able to obtain a TCT. Maximo then sold the entire
land to Narciso. Narciso took possession of the eastern part of the land. The RTC ruled in favour
of the Spouses Magpalo. Narcisso appealed to the CA and obtained a favourable ruling based on
technicality, it ruled in favour of Narcisso since the contract of sale is only voidable and the
action for it has already prescribed.

Issue: Whether or not the contract is voidable

Held: No, the contract is not voidable but void. The contract of purchase and sale is null and
void and produces no effect whatsoever where the same is without cause or consideration in that
purchase price which appears thereon as paid, has in fact never been paid by the purchaser or the
vendor.
Ong v. Ong

G.R. No. L-67888 October 8, 1985

Facts: Imelda Ong for a consideration of P1.00 and other valuable consideration executed in
favor of private respondent Sandra Maruzzo, then a minor, a Quitclaim Deed whereby she
transferred, released, assigned and forever quit-claimed to Sandra Maruzzo, her heirs and
assigns, all her rights, title, interest and participation in the ONE-HALF () undivided portion of
the parcel of land in Makati. On November 19, 1980, Imelda Ong revoked the aforesaid Deed of
Quitclaim and, thereafter, on January 20, 1982 donated the whole property described above to
her son, Rex Ong-Jimenez. Sandra Maruzzo through her guardian an action for recovery of
possession and nullification of the donation. Petitioner contented that the quitclaimed executed to
Sandra Maruzzo is equivalent to donation and acceptance of which by the donee is necessary to
give it validity. Further, it is averred that the donee, Sandra Maruzzo, being a minor, had no legal
personality and therefore incapable of accepting the donation. Futhermore, Petitioners appealed
to the respondent Intermediate Appellate Court. They reiterated their argument below and, in
addition, contended that the One (P1.00) Peso consideration is not a consideration at all to
sustain the ruling that the Deed of Quitclaim is equivalent to a sale. Lower courts rule in favour
of Sandra Maruzzo.

Issue: WON the P1.00 and other valuable consideration is enough to validate the contract. YES

Held: Yes, bad faith and inadequacy of the monetary consideration do not render a conveyance
inexistent, for the assignor's liberality may be sufficient cause for a valid contract (Article 1350,
Civil Code), whereas fraud or bad faith may render either rescissible or voidable, although valid
until annulled, a contract concerning an object certain entered into with a cause and with the
consent of the contracting parties, as in the case at bar. In the case at bar it was proven that the
cause or consideration is not the One (P1.00) Peso alone but also the other valuable
considerations.
Bagnas v. CA

G.R. No. L-38498 August 10, 1989

Facts: Hilario Mateum of Kawit, Cavite, died on March 11, 1964, single, without ascendants or
descendants, and survived only by collateral relatives, of whom petitioners herein, his first
cousins, were the nearest. Mateum left no will, no debts, and an estate consisting of twenty-nine
parcels of land in Kawit and Imus, Cavite. The respondents Retonil et al as collateral relatives of
Mateum though more remote in degree than the petitioners, registered with the Registry of
Deeds for the Province of Cavite two deeds of sale purportedly executed by Mateum in their
(respondents') favor covering ten parcels of land. Both deeds were in Tagalog. The consideration
of which are P1.00 and services rendered, being rendered and to be rendered for Hilario Mateum
(nursing him in his old age). The petitioners averred that the deeds of sale are fictitious, non-
existent and alternately as donation is void for lack of acceptance in public instrument. The
respondent on the other hand said in their defense that the petitioners cannot impugn the sale
since they are only collateral relatives and no evidence of fraud is present. The lower courts rule
in favour of the respondents using the Armentia ruling, stating that collateral relatives cannot
impugn voidable contract of sale.

Issue: WON the consideration of the contract is valid and sufficient. NO

Held: The fact that the law as it is now (during the time of Armentia) no longer deems contracts
with a false cause, or which are absolutely simulated or fictitious, merely voidable, but declares
them void, i.e.,inexistent (nulo) unless it is shown that they are supported by another true and
lawful cause or consideration NOT A VALID SALE. Upon the consideration alone that the
apparent gross, not to say enormous, disproportion between the stipulated price in each deed of
P1 plus unspecified and unquantilled services and the undisputable valuable real estate allegedly
sold (worth at least P10,500.00) plainly and unquestionably demonstrates that they state a false
and fictitious consideration, and no other true and lawful cause having been shown, the Court
finds both said deeds, insofar as they purport to be sales,not merely voidable, but void ab initio.