Ralla v Ralla | G.R. No 78646 | July 23, 1991 | Cruz, J.

Doctrine: General Rule: one having no right or interest to protect cannot invoke the
jurisdiction of the court as a party-plaintiff in an action.

Facts:
 Rosendo Ralla had 2 sons: Pablo and Pedro
 Pablo was favored by his father and lived on and administered the latter’s property,
earning P250.00 plus part of the proceeds.
 Pedro lived with his mother and had a strained relationship with his father.
 Their mother died and the brothers partitioned 63 parcels of land in her paraphernal
property.
 Prior to his death, Rosendo disinherited Pedro, willed all his properties to Pablo. He died
during the pendency of the proceedings for probate of the will.
 Rosendo also previously sold to Pable 149 parcels of land for P10,000.00
 November 3, 1966: the probate judge converted SP 564 into an intestate proceeding.
 May 19, 1972: Pedro filed a complaint to annul the sale made by Rosendo to Pablo for
being simulated.
 RTC: sale null and void. Pedro files a motion for reconsideration.
 RTC: sale valid.
 CA: sale null and void.
 February 28, 1978: a creditor of the deceased filed a petition for the probate of Rosendo's
will in SP 1106, which was heard jointly with SP 564.
 August 3, 1979: the order of November 3, 1966, was set aside.
 RTC: The last will and testament of Rosendo was allowed but Pedro’s disinheritance was
disapproved.
 July 25, 1986, CA: reversed the RTC and reinstated the disinheritance clause finding valid
cause for Pedro’s disinheritance.
 Pedro previously threatened to kill Rosendo and was sued by the latter for slander and
grave oral defamation.
 SC: dismissed the petition assailing the CA decision for lack of showing of grave abuse of
discretion and for their motion for extension to file a motion for reconsideration being filed
out of time and after the denial of the motion for extension, the petition was still filed 30 days
later from date of notice of denial.
 October 26, 1987: motion for reconsideration denied with finality

Issue:
W/N the sale made by Rosendo to Pablo is valid-NO, but the Court needs to rule on
Pedro’s standing to question the transaction
 The Court agrees with the CA ruling that the sale in null and void.
 However, since Pedro’s disinheritance was affirmed by the CA, his interest in the matter of
transaction between his late father and his brother is in question.
 Interest: 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.
 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.
 General Rule: one having no right or interest to protect cannot invoke the jurisdiction of
the court as a party-plaintiff in an action.
 Since Pablo is the sole heir of his father’s estate, it is just fitting that he acquires ownership
of it all after paying the debts owed.
 What Rosendo sold to Pablo was his share in the conjugal estate, the 149 parcels are thos
which he owned himself and was subject of Pablo’s inheritance in the aforementioned will.
 Further, when Pedro’s heir substituted him after his death, they failed to comply with
submitting memoranda even after an extension was granted to them.
 In conclusion, Pedro, 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.
 Pedro Ralla is a stranger to the transaction between Rosendo and Pablo and does not
stand to benefit from or be prejudiced by it.

Ruling: CA decision set aside.