Resident Marine Mammals of the Protected Seascape Tañon Strait v.

Secretary Angelo
Reyes, G.R. No. 180771 (April 21, 2015)
As to standing, the Court declined to extend the principle of standing beyond natural and juridical
persons, even though it recognized that the current trend in Philippine jurisprudence “moves
towards simplification of procedures and facilitating court access in environmental cases.” Id., p.
15. Instead, the Court explained, “the need to give the Resident Marine Mammals legal standing
has been eliminated by our Rules, which allow any Filipino citizen, as a steward of nature, to bring
a suit to enforce our environmental laws.”

Rule 3
Parties to Civil Actions

Section 1. Who may be parties; plaintiff and defendant. - Only natural or juridical persons, or entities
authorized by law may be parties in a civil action. The term "plaintiff may refer to the claiming party, the
counter-claimant, the cross-claimant, or the third (fourth, etc.)-party plaintiff. The term "defendant" may refer
to the original defending party, the defendant in a counterclaim, the cross-defendant, or the third (fourth,
etc.)-party defendant.

Sec. 2. Parties in interest. - A real party in interest is the party who stands to be benefited or injured by the
judgment in the suit, or the party entitled to the avails of the suit. Unless otherwise authorized by law or these
Rules, every action must be prosecuted or defended in the name of the real party in interest.

Sec. 3. Representatives as parties. - Where the action is allowed to be prosecuted or defended by a

representative or someone acting in a fiduciary capacity, the beneficiary shall be included in the title of the
case and shall be deemed to be the real party in interest. A representative may be a trustee of an express
trust, a guardian, an executor or administrator, or a party authorized by law or these Rules. An agent acting
in his own name and for the benefit of an undisclosed principal may sue or be sued without joining the principal
except when the contract involves things belonging to the principal.

DONALD FRANCIS GAFFNEY, PETITIONER, VS. GINA V. BUTLER,

RESPONDENT.

The deceased or his estate may not be named a defendant in the present case.

A deceased person does not have the capacity to be sued and may not be made a defendant in a case.[25] Section 1,
Rule 3 of the Revised Rules of Court unequivocally states that "[o]nly natural or juridical persons, or entities authorized
by law may be parties in a civil action."

Applying this legal provision, the Court, in Ventura v. Militante,[26] declared that neither a deceased person nor his
estate has capacity to be sued

The rule is no different as regards party defendants. It is incumbent upon a plaintiff, when he institutes a judicial
proceeding, to name the proper party defendant to his cause of action. [19] In a suit or proceeding in personam of an
adversary character, the court can acquire no jurisdiction for the purpose of trial or judgment until a party defendant
who actually or legally exists and is legally capable of being sued, is brought before it. It has even been held that the
question of the legal personality of a party defendant is a question of substance going to the jurisdiction of the court
and not one of procedure.

x x x x

Neither a dead person nor his estate may be a party plaintiff in a court action. A deceased person does not
have such legal entity as is necessary to bring action so much so that a motion to substitute cannot lie and
should be denied by the court. An action begun by a decedent's estate cannot be said to have been begun by a legal
person, since an estate is not a legal entity; such an action is a nullity and a motion to amend the party plaintiff will not
likewise lie, there being nothing before the court to amend. Considering that capacity to be sued is a correlative of
the capacity to sue, to the same extent, a decedent does not have the capacity to be sued and may not be
named a party defendant in a court action.[27] (Emphasis supplied; citations omitted)

Hence, there can be no doubt that a deceased person or his estate may not be impleaded as defendant in a civil action
as they lack legal personality. Thus, when Anthony died, his legal personality ceased and he could no longer be
impleaded as respondent in the present ordinary civil suit for collection.[28] As such, the complaint against him should
be dismissed on the ground that the pleading asserting the claim states no cause of action or for failure to state a cause
of action pursuant to Section 1(g), Rule 16 of the Rules of Court, because a complaint cannot possibly state a cause
of action against one who cannot be a party to a civil action.