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	GR No. 138437 2008-11-14	RAMON J. QUISUMBING v. SANDIGANBAYAN CARPIO MORALES, J.
"Interest" within the meaning of the immediately-quoted Rule means material interest or an interest in issue to be affected by the decree, as distinguished from mere interest in the question involved or a mere incidental interest. Otherwise stated, the Rule refers to a real or present substantial interest as distinguished from a mere expectancy, or a future, contingent, subordinate or consequential interest. As a general rule, one who has no right or interest to protect cannot invoke the jurisdiction of a court as a party-plaintiff in an action;[21] if he does, the suit is dismissible on the ground of lack of cause of action.[22]
	GR NO. 164787 2006-01-31	MARLENE CRISOSTOMO v. FLORITO M. GARCIA CHICO-NAZARIO, J.
The four-year prescriptive period relied upon by the petitioners apply only if the complaint seeks to annul a voidable contract under Article 1390[32] of the Civil Code. In such case, the four-year prescriptive period under Article 1391[33] begins to run from the time of discovery of the mistake, violence, intimidation, undue influence or fraud.[34]