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Thursday, June 14, 2012

Digest Case in Civil Procedure-Party In Interest

G.R. No. 161065. April 15, 2005
EUFEMIO C. DOMINGO, CELSO D. GANGAN, PACASIO S. BANARIA, SOFRONIO B. URSAL, ALBERTO P. CRUZ, MARIA L. MATIB, RACHEL U. PACPACO, ANGELO G. SANCHEZ, and SHERWIN A. SIP-AN, Petitioners, 
vs.
HON. GUILLERMO N. CARAGUE, in his capacity as Chairman, Commission on Audit, HON. EMMANUEL M. DALMAN and HON. RAUL C. FLORES, in their capacities as Commissioners, Commission on Audit,Respondents.
s jurisdiction and justify the exercise of judicial power on his behalf.
FACTS:
This case was a petition for certiorari is the legality of a resolution No. of the Commission on Audit (COA) providing for Organizational Restructuring Plan. The petitioners alleged therein that this Plan is intrinsically void for want of an enabling law which gives that COA to undertake the same and providing for the necessary standards, conditions, restrictions, limitations, guidelines, and parameters. Petitioners further alleged COA committed grave abuse of discretion amounting to lack or excess of jurisdiction. Respondents, through the Office of the Solicitor General (OSG), countered that petitioners have no legal standing to file the present petition since they have not shown "a personal stake in the outcome of the case" or an actual or potential injury that can be redressed by our favorable decision. In essence, it is alleged that the petitioners are not a party in interest, but the petitioners claim otherwise by reason that the matter is of public concern. The said Organizational Restructuring Plan is not just a mere reorganization but a revamp or overhaul of the COA, with a "spillover effect" upon its audit performance. This will have an impact upon the rest of the government bodies subject to its audit supervision, thus, should be treated as a matter of transcendental importance.
ISSUE: Whether petitioners have the legal standing to institute the instant petition.
HELD: The Supreme Court decided, NO.It stated that:
(Locus Standi)
There was no showing that they had any direct and personal interest in the COA Organizational Restructuring Plan. There was also of an admission that "they do not seek any affirmative relief nor impute any improper or improvident act against the respondents" and "are not motivated by any desire to seek affirmative relief from COA or from respondents that would redound to their personal benefit or gain." Hence, the petitioners do not have any legal standing to file the instant suit. This case was decided by the Supreme Court En Banc.
He who is directly affected and whose interest is immediate and substantial has the standing to sue.  A party must show a personal stake in the outcome of the case or an injury to himself that can be redressed by a favorable decision in order to warrant an invocation of the court

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