CARO V. SUCALDITO (REMEDIAL)

Under Section 2, Rule 3 of the Rules of Court, every action must be prosecuted or defended in the name of the REAL PARTY-IN-INTEREST or one "who stands to be benefited or injured by the judgment in the suit." Corollarily, LEGAL STANDING has been defined as a personal and substantial interest in the case, such that the party has sustained or will sustain direct injury as a result of the challenged act. Interest means a material interest in issue that is affected by the questioned act or instrument, as distinguished from a mere incidental interest in the question involved.

Clearly then, a suit filed by one who is not a party-in-interest must be dismissed. In this case, the petitioner, not being the owner of the disputed property but a mere applicant for a free patent, cannot thus be considered as a party-in-interest with personality to file an action for reconveyance.

As held in Lucas v. Durian: the proper party to bring the action was the government, to which the property would revert.

As declared in Nebrada v. Heirs of Alivio: plaintiff, being a mere homestead applicant, was not the real party-in-interest to institute an action for reconveyance.

If the suit is not brought in the name of or against the real party-in-interest, a motion to dismiss may be filed on the ground that the complaint states no cause of action. In fact, a final judgment may be invalidated if the real party-in-interest are not included. Final judgments are nullified when indispensable parties are not impleaded.

In the present dispute, only the State can file a suit for reconveyance of public land. Therefore, not being the owners of the land but mere applicants for sales patents thereon. respondents have no personality to file the suit. Neither will they be directly affected by the judgment in such a suit.