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VSC COMMERCIAL ENTERPRISES v. CA

This case has been cited 3 times or more.

2006-08-31
YNARES-SANTIAGO, J.
As regards the standing of the purported farmer-beneficiaries who sought to intervene in the said case the recognized 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.[18] 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 more incidental interest.[19] Real Interest means a present substantial interest, as distinguished from a mere expectancy or a future, contingent, subordinate or consequential interest.[20]
2006-05-31
PUNO, J.
These provisions bar JULAG-AY from contesting the title of his landlord, i.e., the Estate or its representative. This Court has consistently held that lessees who have had undisturbed possession for the entire term under the lease, like JULAG-AY, are estopped to deny their landlord's title, or to assert a better title not only in themselves, but also in some third person, while they remain in possession of the leased premises and until they surrender possession to the landlord.[15] It is of no significance that JULAG-AY is not claiming title to the property for himself. Estoppel still applies to him, as he enjoyed the use of the property without interruption from 1995.
2005-05-16
CALLEJO, SR., J.
In VSC Commercial Enterprises, Inc. v. Court of Appeals,[38] where the private respondents therein were mere lessees of the property in question, the Court ruled that as mere lessees, they had "no present substantial and personal interest with respect to issues involving ownership of the disputed property." The Court went on to declare:... The only interest they have, in the event the petitioner's title over the subject property is cancelled and ownership reverts to the State, is the hope that they become qualified buyers of the subject parcel of land. Undoubtedly, such interest is a mere expectancy. Even the private respondents themselves claim that in case of reversion of ownership to the State, they only have "pre-emptive rights" to buy the subject property; that their real interest over the said property is contingent upon the government's consideration of their application as buyers of the same. It is settled that a suit filed by a person who is not a party-in-interest must be dismissed.[39]