7/25/2019 Carandang vs. de Guzman - Proforma Parties

1/2

TOPIC: RULE ON COMPULSORY JOINDER OF INDISPENSABLE PARTIES (CO-OWNERS OF PERSONAL PROPERTIES)

NATURE OF THE CASE: This case reached the Supreme Court as an appeal to the decision of the CA ruling against the spouses

Carandang and denying their motion for reconsideration. The CA affirmed the RTCs decision that Milagros de Guzman, the decedents wife,

is not an indispensale party in the complaint, hence, her non!inclusion in the case does not warrant a dismissal of the complaint.

FACTS: Spouses Carandang and the decedent "uirino de Guzman were stoc#holders and corporate officers of Mauhay $roadcasting

System %M$S&. The Carandangs ha'e e(uities at )* + while "uirino has *+.

-hen the capital stoc# of M$S was increased on o'emer /, 0123, the Carandangs suscried 43*),555 from it, 4/13,/)5 from

the said amount was loaned y "uirino to the Carandangs. 6n the suse(uent increase in M$S capital stoc# on March 3, 0121, the

Carandangs suscried again to the increase in the amount of 413,7)5. $ut, 4*3,0/) out of the mentioned amount was again loaned y

"uirino.

-hen "uirino sent a demand letter to the Carandangs for the payment of the loan, the Carandangs refused to pay. They contend

that a pre!incorporation agreement was e8ecuted etween Arcadio Carandang and "uirino, wherey "uirino promised to pay for the stoc#

suscriptions of the Arcadio without cost, in consideration for Arcadios technical e8pertise, his newly purchased e(uipment, and his s#ill in

repairing and upgrading radio9communication e(uipment therefore, there is no indetedness on the part of the Carandangs.

Thereafter, "uirino filed a complaint see#ing to reco'er the 433,37) total amount of the loan together with damages. The RTC ruled in

fa'or of "uirino and ordered the Carandangs to pay the loan plus interest, attorneys fees, and costs of suit. The Carandangs appealed the

trial courts decision to the CA, ut the CA affirmed the same. The suse(uent Motion for Reconsideration filed y the Carandangs were also

denied. :ence, this appeal to the SC.

SPOUSES CARANDANG: Three of the four chec#s used to pay their stoc# suscriptions were issued in the name of Milagros de Guzman,

the decedents wife. Thus, Milagros should e considered as an indispensale party in the complaint. $eing such, the failure to ;oin Milagros

as a party in the case should cause the dismissal of the action y reason of a ;urisprudence stating that< =%i&f a suit is not rought in the name

of or against the real party in interest, a motion to dismiss may e filed on the ground that the complaint states no cause of action.>

ISSUE: -hether or not the RTC should ha'e dismissed the case for failure to state a cause of action, considering that Milagros de Guzman,

allegedly an indispensale party, was not included as a party!plaintiff.

HELD:o. Although the spouses Carandang were correct in in'o#ing the aforementioned doctrine, the ground set forth entails an

e8amination of =whether the parties presently pleaded are interested in the outcome of the litigation, and notwhether all persons interested

in such outcome are actually pleaded.? The first (uery see#s to answer the (uestion of whether Milagros is a real party in interest, while the

latter (uery is as#ing if she is an indispensale party. Since the issue of this case calls for the definition of an indispensale party, in'o#ing

the ao'ementioned doctrine is irrele'ant to the case ecause the doctrine tal#s aout a @real party in interest and not an @indispensale

party. Although it is important to ta#e note that an indispensale party is also a real party in interest.

Befinitions