V-GENT, INC.

v MORNING STAR TRAVEL

G.R. No. 186305 | July 22, 2015
Brion, J. | Protacio

Nature of the Case

Petition for review on certiorari challenging the CA decision

How did it get to the Supreme Court

- Morning Star files a money claim before the MeTC of Manila
o MeTC dismissed the complaint for lack of cause of action
o V-Gent declared agent of the buyers, but that V-Gent failed to prove its
case
- RTC reversed the MeTC judgement
- Morning Star elevated the case to the CA
o Ruled that V-Gent is not the real party in interest – because it merely
acted as an agent of the passengers
o MR denied by CA
- Hence, this petition.

Summary of Facts
After buying 26 two-way plane tickets from Morning Star Travel and Tours, Inc., V-Gent
Inc returned 15 unused tickets to the respondent, who only refunded six tickets.
Despite demand, Morning Star refused to refund the nine remaining tickets, so V-Gent
filed a money claim against Morning Star. Morning Star questions the personality of V-
Gent to file the action as it is the passengers who bought the tickets, who are the real
parties in interest.

Doctrine
1. Every action must be prosecuted or defended in the name of the real party-
in-interest (party who stands to be benefited or injured by the judgment in the
suit)
a. In suits where an agent represents a party, the principal is the real party-
in-interest; an agent cannot file a suit in his own name
2. Rule 3, Section 3 Rules of Court provides an exception when an agent may
sue or be sued without the principal; elements:
a. Agent acted in his own name during the transaction
b. Agent acted for the benefit of an undisclosed principal
c. Transaction did not involve the property of the principal
3. Only the first element is present
a. Purchase order and receipt were in the name of V-Gent
b. But V-gent disclosed the names of the passengers
c. Transaction paid by passenger’s money
4. As for claims that by making a partial refund, Morning Star was estopped from
refusing a full refund on the ground that V-Gent is not a real party-in-interest
a. Morning Star’s recognition of V-Gent’s authority to collect a refund is not
equivalent to recognition of V-Gent’s authority to initiate a suit on
behalf of the passengers
i. Morning Stasr not estopped from questioning legal standing to
inititate suit