**Facts:**
1. Sometime between 2006 to 2007, Gina V. Butler and her husband Anthony Richard Butler approached Donald Francis Gaffney and invited him to invest in ActiveFun Corporation, a company that specializes in children’s play and party facilities.
2. Donald invested approximately PHP 12,500,000.00 in ActiveFun.
3. In December 2009, Anthony Richard Butler passed away, preventing the proposed investment agreement from materializing.
4. Donald demanded the return of his investment from Gina, who promised to repay the amount with accrued interest.
5. On October 15, 2010, Gina paid Donald an initial amount of PHP 1,000,000.00, which Donald acknowledged in writing.
6. Despite several demands, Gina failed to repay the remaining amount.
7. On July 13, 2011, Donald sent a formal demand letter to Gina requiring payment within ten days.
8. Gina responded on August 2, 2011, denying any knowledge of the investments and any obligation to repay.
9. On September 21, 2011, Donald filed a Complaint for sum of money against Gina.
**Procedural Posture:**
1. Gina filed an Answer on April 23, 2012, denying knowledge of the investment and claiming that her acknowledgment of the PHP 1,000,000.00 payment was misled by intimidation.
2. Donald filed a Motion for Leave to Admit Amended Complaint to include the estate of Anthony Richard Butler.
3. The RTC granted the motion, and an Alias Summons was served upon Gina as the alleged representative of her late husband.
4. Gina filed a Motion to Dismiss claiming that the estate of a deceased person could not be sued in an ordinary civil action.
5. Donald filed a Motion to Declare Defendant in Default for Gina’s failure to answer the Amended Complaint within the period.
6. On August 15, 2013, the RTC denied both motions, and upon Gina’s subsequent Motion for Reconsideration Ad Cautelam, the RTC reaffirmed its decision on November 25, 2013.
7. Gina filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA) to nullify the RTC Orders.
8. The CA granted Gina’s petition, setting aside the RTC orders and dismissing the entire complaint on February 6, 2015.
9. Donald’s Motion for Reconsideration was denied by the CA on July 14, 2015, prompting Donald to file a Petition for Review on Certiorari with the Supreme Court.
**Issues:**
1. Whether the CA erred in overturning the RTC’s decision allowing the estate of Anthony Butler to be named as an additional defendant.
2. Whether the CA erred in dismissing the entire complaint including claims against Gina.
**Court’s Decision:**
1. **Issue 1 – Impleading the Estate of Anthony Richard Butler:** The Supreme Court ruled that a deceased person or their estate cannot be sued as they lack legal personality as per Section 1, Rule 3 of the Rules of Court. Thus, Anthony Richard Butler, being deceased, did not have the capacity to be sued when the complaint was filed, and consequently, the RTC did not acquire jurisdiction over Anthony’s estate.
2. **Issue 2 – Dismissal of Entire Complaint Against Gina:** The Supreme Court agreed with Donald that the CA exceeded its authority by dismissing the entire complaint as it was based on issues not raised in the original petitions. The CA should have confined its ruling to the issues presented.
**Doctrine:**
1. **Legal Capacity and Jurisdiction:** A deceased individual and their estate cannot be parties in an ordinary civil suit. Legal capacity to be sued is necessary to confer jurisdiction.
2. **Scope of Judgments:** Courts cannot grant relief beyond the scope of the issues raised and prayed for in the pleadings due to due process requirements.
**Class Notes:**
– *Legal Personality:* Only natural or juridical persons can be parties in a lawsuit (Sec. 1, Rule 3, 1997 Rules of Civil Procedure).
– *Jurisdiction over Estate:* A court cannot acquire jurisdiction over a deceased person’s estate in a regular civil action; claims must be made in proper special proceedings for the estate.
– *Due Process:* Judicial relief granted by a court must align with the issues and prayers presented in the pleadings (Boston Equity Resources, Inc. v. Court of Appeals).
**Historical Background:**
– This case underscores procedural nuances in the Philippines’ legal system, especially in understanding the interplay between ordinary civil actions and the settlement of estates. It emphasizes the necessity for proper procedural adherence and the limitations of courts in granting relief beyond the scope of what is contested, rooted in principles of due process and jurisdiction.
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