RULE 3, SECTIONS 1 – 3: PARTIES TO A CIVIL ACTION

78.)PABLO RALLA vs. PEDRO RALLA

G.R. No. 78646, July 23, 1991
What is involved in the present petition is the correctness of the decision of the Court of Appeals
annulling the deed of sale executed by Rosendo Ralla in favor of Pablo over 149 parcels of land. The
original decision of the trial court declared the sale null and void. In the resolution of the motion for
reconsideration, however, Judge Jose F. Madara completely reversed himself and held the deed of
sale to be valid. This order was in turn set aside by the Court of Appeals, which reinstated the
original decision invalidating the deed of sale.

FACTS:

Rosendo Ralla had two sons, Pablo and Pedro. The father apparently loved the former but not the
latter, Pablo and his family lived with Rosendo, while Pedro lived with his mother, Paz Escarella, in
another town. He was not on good terms with his father. Paz Escarella later on died and the two
brothers partitioned 63 parcels of land she left.

Meanwhile, Rosendo executed a will disinheriting Pedro and leaving everything he owned to Pablo,
to whom he said he had earlier sold a part of his property for P10,000.00. Rosendo himself filed for
the probate of the will but pendente lite died on October 1, 1960.

The last will and testament of Rosendo Ralla was allowed but the disinheritance of Pedro was
disapproved. This order was elevated to the Court of Appeals.The Court of Appeals reversed the
trial court and reinstated the disinheritance clause after finding that the requisites of a valid
disinheritance had been complied with in the will.The decision was assailed before this Court which
was dismissed in our resolution. The motion for reconsideration was denied with finality.

The Court is inclined to support the findings of the respondent court. However, we do not and
cannot make any decision on this matter because of one insuperable obstacle. That obstacle is the
proper party personality of Pedro Ralla to question the transaction.

ISSUE:

Whether Pedro Ralla has a legal personality to question the deed of sale between Rosendo Ralla and
his son Pablo.

RULING:

Pedro Ralla has no legal personality to question the deed of sale.

The decision of the Court of Appeals in AC-G.R. Nos. 00472, 00489 approved the disinheritance of
Pedro Ralla. That decision was appealed to this Court, but the petition for review was dismissed.
The decision has long since become final. Since then, Pedro Ralla no longer had the legal standing to
question the validity of the sale executed by Rosendo in favor of his other son Pablo.

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 issue and to be affected by the decree, as distinguished from mere interest in
the question involved, or a mere incidental interest. As a general rule, one having no right or
interest to protect cannot invoke the jurisdiction of the court as a party-plaintiff in an action.

Our decision is that as a validly disinherited heir, and not claiming to be a creditor of his deceased
father, Pedro Ralla had no legal personality to question the deed of sale dated November 29, 1957,
between Rosendo Ralla and his son Pablo. Legally speaking, Pedro Ralla was a stranger to the
transaction as he did not stand to benefit from its annulment. His disinheritance had rendered
him hors de combat.