Fortich vs.

Corona

G.R. No. 131457

April 24, 1998

Ponente: Martinez, J.

Doctrine: Real party in intetest

The strikers protested the March 29, 1996 Decision of the Office of the President (OP), issued through
then Executive Secretary Ruben D. Torres in OP Case No. 96-C-6424, which approved the conversion of a
one hundred forty-four (144)-hectare land from agricultural to agro-industrial/institutional area. This led
the Office of the President, through then Deputy Executive Secretary Renato C. Corona, to issue the so-
called Win-Win Resolution on November 7, 1997, substantially modifying its earlier Decision after it had
already become final and executory. The said Resolution modified the approval of the land conversion to
agro-industrial area only to the extent of forty-four (44) hectares, and ordered the remaining one
hundred (100) hectares to be distributed to qualified farmer-beneficiaries.

A motion for intervention was filed by alleged farmer-beneficiaries. In their motion, movants contend
that they are the farmer-beneficiaries of the land in question, hence, are real parties in interest. To prove
this, they attached as Annex I in their motion a Master List of Farmer-Beneficiaries. Apparently, the
alleged master list was made pursuant to the directive in the dispositive portion of the assailed Win-Win
Resolution which directs the DAR to carefully and meticulously determine who among the claimants are
qualified farmer-beneficiaries. However, a perusal of the said document reveals that movants are those
purportedly Found Qualified and Recommended for Approval. In other words, movants are merely
recommendee farmer-beneficiaries.

Issue: WON the farmers-beneficiaries are real party in interest

Held:

No.

The rule in this jurisdiction is that a real party in interest is a party who would be benefited or injured by
the judgment or is the party entitled to the avails of the suit. Real interest means a present substantial
interest, as distinguished from a mere expectancy or a future, contingent, subordinate or consequential
interest. Undoubtedly, movants interest over the land in question is a mere expectancy. Ergo, they are
not real parties in interest.