Plaintiff-appellant Sulo ng Bayan Inc., a corporation, filed a lawsuit against defendant-appellees to recover ownership of a large tract of land registered under the Torrens system in the name of defendants' predecessors. Plaintiff claimed its members had pioneered and continuously possessed the land since the Spanish regime. However, the trial court dismissed the complaint. On appeal, the Court of Appeals certified the case to the Supreme Court to resolve the legal issues. The Supreme Court ruled that as the corporation did not claim its members assigned their land rights to the corporation, and absent any showing of interest in the land, the corporation did not have legal standing to bring a lawsuit on behalf of its members to recover land belonging to the members personally
Plaintiff-appellant Sulo ng Bayan Inc., a corporation, filed a lawsuit against defendant-appellees to recover ownership of a large tract of land registered under the Torrens system in the name of defendants' predecessors. Plaintiff claimed its members had pioneered and continuously possessed the land since the Spanish regime. However, the trial court dismissed the complaint. On appeal, the Court of Appeals certified the case to the Supreme Court to resolve the legal issues. The Supreme Court ruled that as the corporation did not claim its members assigned their land rights to the corporation, and absent any showing of interest in the land, the corporation did not have legal standing to bring a lawsuit on behalf of its members to recover land belonging to the members personally
Plaintiff-appellant Sulo ng Bayan Inc., a corporation, filed a lawsuit against defendant-appellees to recover ownership of a large tract of land registered under the Torrens system in the name of defendants' predecessors. Plaintiff claimed its members had pioneered and continuously possessed the land since the Spanish regime. However, the trial court dismissed the complaint. On appeal, the Court of Appeals certified the case to the Supreme Court to resolve the legal issues. The Supreme Court ruled that as the corporation did not claim its members assigned their land rights to the corporation, and absent any showing of interest in the land, the corporation did not have legal standing to bring a lawsuit on behalf of its members to recover land belonging to the members personally
Plaintiff-appellant Sulo ng Bayan Inc., a corporation, filed a lawsuit against defendant-appellees to recover ownership of a large tract of land registered under the Torrens system in the name of defendants' predecessors. Plaintiff claimed its members had pioneered and continuously possessed the land since the Spanish regime. However, the trial court dismissed the complaint. On appeal, the Court of Appeals certified the case to the Supreme Court to resolve the legal issues. The Supreme Court ruled that as the corporation did not claim its members assigned their land rights to the corporation, and absent any showing of interest in the land, the corporation did not have legal standing to bring a lawsuit on behalf of its members to recover land belonging to the members personally
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G.R. No.
L-31061 August 17, 1976
SULO NG BAYAN INC., plaintiff-appellant, vs. GREGORIO ARANETA, INC., PARADISE FARMS, INC., NATIONAL WATERWORKS & SEWERAGE AUTHORITY, HACIENDA CARETAS, INC, and REGISTER OF DEEDS OF BULACAN, defendants-appellees. FACTS: Plaintiff-appellant Sulo ng Bayan, Inc. filed an accion de revindicacion with the Court of First Instance against defendants-appellees to recover the ownership and possession of a large tract of land registered under the Torrens System in the name of defendants-appellees' predecessors-in-interest. plaintiff is a corporation organized and existing under the laws of the Philippines, that its membership is composed of natural persons; that the members of the plaintiff corporation, through themselves and their predecessors-in-interest, had pioneered in the clearing of the fore-mentioned tract of land, cultivated the same since the Spanish regime and continuously possessed the said property openly and public under concept of ownership adverse against the whole world; that defendant-appellee Gregorio Araneta, Inc., through force and intimidation, ejected the members of the plaintiff corporation from their possession of the aforementioned vast tract of land; that upon investigation conducted by the members and officers of plaintiff corporation, they found out for the first time that the land in question "had been either fraudelently or erroneously included, by direct or constructive fraud, in Original Certificate of Title of the Land of Records of the province of Bulacan", which title is fictitious, non-existent and devoid of legal efficacy due to the fact that "no original survey nor plan whatsoever" appears to have been submitted as a basis thereof and that the Court which issued the decree of registration did not acquire jurisdiction over the land registration case because no notice of such proceeding was given to the members of the plaintiff corporation who were then in actual possession of said properties, that as a consequence of the nullity of the original title, all subsequent titles derived therefrom, are therefore void. Defendant-appellee Gregorio Araneta, Inc. filed a motion to dismiss the amended complaint on the grounds that (1) the complaint states no cause of action; and (2) the cause of action, if any, is barred by prescription and laches. The trial court issued an Order dismissing the amended complaint. Appellant filed a motion to reconsider the Order of dismissal. This motion was denied by the trial court in. From the afore-mentioned Order of dismissal and the Order denying its motion for reconsideration, plaintiff-appellant appealed to the Court of Appeals. The Court of Appeals, upon finding that no question of fact was involved in the appeal but only questions of law and jurisdiction, certified this case to this Court for resolution of the legal issues involved in the controversy. ISSUE: Whether or not plaintiff corporation (non- stock may institute an action in behalf of its individual members for the recovery of certain parcels of land allegedly owned by said members; for the nullification of the transfer certificates of title issued in favor of defendants appellees covering the aforesaid parcels of land; for a declaration of "plaintiff's members as absolute owners of the property" and the issuance of the corresponding certificate of title; and for damages? RULING: No, It has not been claimed that the members have assigned or transferred whatever rights they may have on the land in question to the plaintiff corporation. Absent any showing of interest, therefore, a corporation, like plaintiff-appellant herein, has no personality to bring an action for and in behalf of its stockholders or members for the purpose of recovering property which belongs to said stockholders or members in their personal capacities. It is fundamental that there cannot be a cause of action 'without an antecedent primary legal right conferred' by law upon a person. Evidently, there can be no wrong without a corresponding right, and no breach of duty by one person without a corresponding right belonging to some other person. Thus, the essential elements of a cause of action are legal right of the plaintiff, correlative obligation of the defendant, an act or omission of the defendant in violation of the aforesaid legal right. Clearly, no right of action exists in favor of Plaintiff Corporation, for as shown heretofore it does not have any interest in the subject matter of the case which is material and, direct so as to entitle it to file the suit as a real party in interest.