Case Name: Fortich v Corona

GR No.: 131457

DOCTRINE/S: REAL PARTY IN INTEREST; DEFINED; MOVANTS IN CASE AT BAR ARE NOT REAL PARTIES IN
INTEREST. — 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.

REMEDIAL LAW; ERROR OF JUDGMENT, AS DISTINGUISHED FROM ERROR OF JURISDICTION. — An error

of judgment is one which the court may commit in the exercise of its jurisdiction, and which error is
reviewable only by an appeal. On the other hand, an error of jurisdiction is one where the act complained
of was issued by the court, officer or a quasi-judicial body without or in excess of jurisdiction, or with grave
abuse of discretion which is tantamount to lack or in excess of jurisdiction. This error is correctable only
by the extraordinary writ of certiorari.

FACTS:

-The ‘alleged’ farmer-beneficiaries strikers protested the March 29, 1996 decision of the Office of the
President (OP), which approved the conversion of a 144-hectare land in Bukidnon from agricultural to
agro-industrial institutional area.

-This led the OP, 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 only to the extent of 44 hectares, and
ordered the remaining 100 hectares to be distributed to qualified farmer-beneficiaries.

ISSUE:
a) Whether the “Win-Win” resolution issued by the OP was valid?
b) Were the farmer-beneficiaries real-parties of interest?

RULING:

a) No, the Win-win resolution was null and void, as its issue being already outside the jurisdiction of the
OP.

The rules and regulations governing appeals to the OP are embodied in Administrative Order No. 18, which
provides in Section 7, that: "Decisions become final after the lapse of 15 days from receipt of a copy
thereof by the parties, unless a motion for reconsideration thereof is filed within such period“

When the OP declared the decision of March 29, 1996 final and executory, as the first motion for
reconsideration was not seasonably filed, the said Office had lost its jurisdiction to re-open the case or
modify the decision. Having lost its jurisdiction, the OP has no more authority to entertain the second
motion for reconsideration filed by respondent DAR Secretary, which second motion became the basis of
the assailed "Win-Win" Resolution.
Section 7 of AO No. 18 and Section 4, Rule 43 of the Rules of Court mandate that only one motion for
reconsideration is allowed to be taken from the decision of March 29, 1996.

Thus, the act of the OP in re-opening the case and substantially modifying its March 29, 1996 decision
which had already become final and executory, was in gross disregard of the rules and basic legal precept
that accord finality to administrative determinations. Therefore the Win-Win Resolution was null and void.

b) No, the purported Farmer-beneficiaries were not real-parties in interest to the case.

The court held 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.

In this case, the Win-win resolution being null and void only vests a mere expectancy to the purported
farmer beneficiaries. Therefore they are not real parties in interest