American President Lines v. Malayan Insurance Co.

Summary

This case involves a dispute over legal standing where TMMIC, as settling agent of insurer TMFIC, filed a recovery suit against shipping company APL for damaged cargo. The Supreme Court reversed the Court of Appeals, holding that TMMIC lacked legal personality to file suit as it was merely an agent, not the real party in interest. The Court emphasized that every action must be prosecuted by the real party in interest - the one who stands to be benefited or injured by the judgment. Since TMFIC was the actual insurer who paid the claim and received subrogation rights, it should have filed the suit or been included as a party. The case establishes important precedent on agency relationships in litigation and the requirement that principals, not agents, must sue in their own name unless specific exceptions apply.