William Uy v. Court of Appeals

Summary

William Uy and Rodel Roxas, as authorized agents, sold eight parcels of land in Benguet to the National Housing Authority for a housing project. NHA cancelled the sale of three parcels after discovering they were in an active landslide area unsuitable for development. The agents sued for damages, claiming they suffered losses including unearned commissions and advances. The Supreme Court dismissed their petition, ruling that as mere agents, they were not real parties-in-interest who could sue in their own name under the Rules of Court. The Court held they were not parties to the contract, nor assignees or beneficiaries under the Civil Code. Additionally, the Court found NHA's cancellation was justified based on the geological report, and the cancellation was based on negation of cause rather than rescission under Article 1191. The decision establishes that agents cannot sue for their own damages arising from contracts made on behalf of principals unless they have assigned rights or specific contractual interests beyond mere compensation entitlement.