SUPREME COURT REPORTS ANNOTATED VOLUME 783 1/16/18, 12:29

G.R. No. 181186. February 3, 2016.*

SIGUION REYNA MONTECILLO AND ONGSIAKO LAW

OFFICES, petitioner, vs. HON. NORMA CHIONLO-SIA, in
her capacity as Presiding Judge of Branch 56 of the
Regional Trial Court of Lucena City, and the TESTATE
ESTATE OF DECEASED SUSANO RODRIGUEZ,
represented by the Special Administratrix, respondents.

Remedial Law; Civil Procedure; Parties; Locus Standi; The

general rule is that a person not a party to the proceedings in the
trial court cannot maintain an action for certiorari in the Court of
Appeals (CA) or the Supreme Court (SC) to have the order or
decision of the trial court reviewed.·The general rule is that a
person not a party to the proceedings in the trial court cannot
maintain an action for certiorari in the CA or the Supreme Court to
have the order or decision of the trial court reviewed. Under normal
circumstances, the CA would have been correct in dismissing a
petition for certiorari filed by a nonparty. The peculiar facts of this
case, however, call for a less stringent application of the rule.
Civil Law; Agency; Under the law of agency, an agent is not
personally liable for the obligations of the principal unless he
performs acts outside the scope of his authority or he expressly binds
himself to be personally liable.·Under the law of agency, an agent
is not personally liable for the obligations of the principal unless he
performs acts outside the scope of his authority or he expressly
binds himself to be personally liable. Otherwise, the principal is
solely liable. Here, there was no showing that SRMO bound itself
personally for GerardoÊs obligations. SRMO also acted within the
bounds of the authority issued by Gerardo, as the transferee
pendente lite of the widowÊs interest, to receive the payment.
Remedial Law; Civil Procedure; Parties; Unless the court upon
motion directs the transferee pendente lite to be substituted, the

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SUPREME COURT REPORTS ANNOTATED VOLUME 783 1/16/18, 12:29

action is simply continued in the name of the original party.·

Unless the court upon motion directs the transferee pendente lite to
be substi-

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