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SAN BEDA COLLEGE - SCHOOL OF LAW

Alabang, Muntinlupa City


SPECIAL CIVIL ACTIONS AND SPECIAL PROCEEDINGS
SY 2018-2019
3S & 3A
SPECIAL CIVIL ACTIONS
General Principles
Jurisdiction
Venue
Distinguish from Ordinary Civil Actions
RULE 62: INTERPLEADER
1. Rizal Commercial Banking Corp. v. Metro Container Corp., G.R. No. 127913,
September 13, 2001;

[G.R. No. 127913. September 13, 2001]

RIZAL COMMERCIAL BANKING CORPORATION, petitioner, vs. METRO


CONTAINER CORPORATION, respondent.

DECISION
KAPUNAN, J.:

Assailed in this petition for review on certiorari are the Decision, promulgated on 18
October 1996 and the Resolution, promulgated on 08 January 1997, of the Court of
Appeals in CA-G.R. SP No. 41294.
The facts of the case are as follows:
On 26 September 1990, Ley Construction Corporation (LEYCON) contracted a loan
from Rizal Commercial Banking Corporation (RCBC) in the amount of Thirty Million Pesos
(P30,000,000.00). The loan was secured by a real estate mortgage over a property,
located in Barrio Ugong, Valenzuela, Metro Manila (now Valenzuela City) and covered by
TCT No. V-17223.LEYCON failed to settle its obligations prompting RCBC to institute an
extrajudicial foreclosure proceedings against it. After LEYCONs legal attempts to forestall
the action of RBCB failed, the foreclosure took place on 28 December 1992 with RCBC
as the highest bidder.
LEYCON promptly filed an action for Nullification of Extrajudicial Foreclosure Sale
and Damages against RCBC. The case, docketed as Civil Case No. 4037-V-93, was
raffled to the Regional Trial Court (RTC) of Valenzuela, Branch 172. Meanwhile, RCBC
consolidated its ownership over the property due to LEYCONs failure to redeem it within
the 12-month redemption period and TCT No. V-332432 was issued if favor of the
bank. By virtue thereof, RCBC demanded rental payments from Metro Container
Corporation (METROCAN) which was leasing the property from LEYCON.
On 26 May 1994, LEYCON filed an action for Unlawful Detainer, docketed as Civil
Case No. 6202, against METROCAN before the Metropolitan Trial Court (MeTC) of
Valenzuela, Branch 82.
On 27 May 1994, METROCAN filed a complaint for Interpleader, docketed as Civil
Case No. 4398-V-94 before the Regional Trial Court of Valenzuela, Metro Manila, Branch
75 against LEYCON and RCBC to compel them to interplead and litigate their several
claims among themselves and to determine which among them shall rightfully receive the
payment of monthly rentals on the subject property. On 04 July 1995, during the pre-trial
conference in Civil Case No. 4398-V-94, the trial court ordered the dismissal of the case
insofar as METROCAN and LEYCON were concerned in view of an amicable settlement
they entered by virtue of which METROCAN paid back rentals to LEYCON.
On 31 October 1995, judgment was rendered in Civil Case No. 6202, which among
other things, ordered METROCAN to pay LEYCON whatever rentals due on the subject
premises. The MeTC decision became final and executory.
On 01 February 1996, METROCAN moved for the dismissal of Civil Case No. 4398-
V-94 for having become moot and academic due to the amicable settlement it entered
with LEYCON on 04 July 1995 and the decision in Civil Case No. 6202 on 31 October
1995. LEYCON, likewise, moved for the dismissal of the case citing the same grounds
cited by METROCAN.
On 12 March 1996, the two motions were dismissed for lack of merit. The motions for
reconsideration filed by METROCAN and LEYCON were also denied prompting
METROCAN to seek relief from the Court of Appeals via a petition for certiorari and
prohibition with prayer for the issuance of a temporary restraining order and a writ of
preliminary injunction. LEYCON, as private respondent, also sought for the nullification of
the RTC orders.
In its Decision, promulgated on 18 October 1996, the Court of Appeals granted the
petition and set aside the 12 March 1996 and 24 June 1996 orders of the RTC. The
appellate court also ordered the dismissal of Civil Case No. 4398-V-94. RCBCs motion
for reconsideration was denied for lack of merit in the resolution of 08 January 1997.
Hence, the present recourse.
RCBC alleged, that:
(1) THE DECISION OF THE METROPOLITAN TRIAL COURT IN THE
EJECTMENT CASE BETWEEN METROCAN AND LEYCON DOES NOT
AND CANNOT RENDER THE INTERPLEADER ACTION MOOT AND
ACADEMIC.
(2) WHILE A PARTY WHO INITIATES AN INTERPLEADER ACTION MAY NOT
BE COMPELLED TO LITIGATE IF HE IS NO LONGER INTERESTED TO
PURSUE SUCH CAUSE OF ACTION, SAID PARTY MAY NOT
UNILATERALLY CAUSE THE DISMISSAL OF THE CASE AFTER THE
ANSWER HAVE BEEN FILED. FURTHER, THE DEFENDANTS IN AN
INTERPLEADER SUIT SHOULD BE GIVEN FULL OPPORTUNITY TO
LITIGATE THEIR RESPECTIVE CLAIMS.[1]
We sustain the Court of Appeals.
Section 1, Rule 63 of the Revised Rules of Court[2] provides:

Section 1. Interpleader when proper. - Whenever conflicting claims upon the same
subject matter are or may be made against a person, who claims no interest whatever
in the subject matter, or an interest which in whole or in part is not disputed by the
claimants, he may bring an action against the conflicting claimants to compel them to
interplead and litigate their several claims among themselves.

In the case before us, it is undisputed that METROCAN filed the interpleader action
(Civil Case No. 4398-V-94) because it was unsure which between LEYCON and RCBC
was entitled to receive the payment of monthly rentals on the subject property. LEYCON
was claiming payment of the rentals as lessor of the property while RCBC was making a
demand by virtue of the consolidation of the title of the property in its name.
It is also undisputed that LEYCON, as lessor of the subject property filed an action
for unlawful detainer (Civil Case No. 6202) against its lessee METROCAN. The issue in
Civil Case No. 6202 is limited to the question of physical or material possession of the
premises.[3] The issue of ownership is immaterial therein[4] and the outcome of the case
could not in any way affect conflicting claims of ownership, in this case between RCBC
and LEYCON. This was made clear when the trial court, in denying RCBC's "Motion for
Inclusion x x x as an Indispensable Party" declared that "the final determination of the
issue of physical possession over the subject premises between the plaintiff and the
defendant shall not in any way affect RCBC's claims of ownership over the said premises,
since RCBC is neither a co-lessor or co-lessee of the same, hence he has no legal
personality to join the parties herein with respect to the issue of physical possession vis-
-vis the contract of lease between the parties."[5] As aptly pointed by the MeTC, the issue
in Civil Case No. 6202 is limited to the defendant LEYCON's breach of the provisions of
the Contract of Lease Rentals.[6]
Hence, the reason for the interpleader action ceased when the MeTC rendered
judgment in Civil Case No. 6202 whereby the court directed METROCAN to pay LEYCON
whatever rentals due on the subject premises x x x. While RCBC, not being a party to
Civil Case No. 6202, could not be bound by the judgment therein, METROCAN is bound
by the MeTC decision. When the decision in Civil Case No. 6202 became final and
executory, METROCAN has no other alternative left but to pay the rentals to
LEYCON. Precisely because there was already a judicial fiat to METROCAN, there was
no more reason to continue with Civil Case No. 4398-V-94. Thus, METROCAN moved
for the dismissal of the interpleader action not because it is no longer interested but
because there is no more need for it to pursue such cause of action.
It should be remembered that an action of interpleader is afforded to protect a person
not against double liability but against double vexation in respect of one liability. [7] It
requires, as an indespensable requisite, that conflicting claims upon the same subject
matter are or may be made against the plaintiff-in-interpleader who claims no interest
whatever in the subject matter or an interest which in whole or in part is not disputed by
the claimants.[8] The decision in Civil Case No. 6202 resolved the conflicting claims
insofar as payment of rentals was concerned.
Petitioner is correct in saying that it is not bound by the decision in Civil Case No.
6202. It is not a party thereto. However, it could not compel METROCAN to pursue Civil
Case No. 4398-V-94. RCBC has other avenues to prove its claim. Is not bereft of other
legal remedies. In fact, he issue of ownership can very well be threshed out in Civil Case
No. 4037-V-93, the case for Nullification of Extrajudicial Foreclosure Sale and Damages
filed by LEYCON against RCBC.
WHEREFORE, the petition for review is DENIED and the Decision of the Court of
Appeals, promulgated on 18 October 1996, as well as its Resolution promulgated on 08
January 1997, are AFFIRMED.
SO ORDERED.

Facts: For failure of Ley Construction Corporation (LEYCON) to settle its loan obligations,
Rizal Commercial Banking Corporation (RCBC) instituted an extrajudicial foreclosure
proceeding against it. In a bidding, RCBC was adjudged the highest bidder. LEYCON
promptly filed an action for Nullification of Extrajudicial Foreclosure Sale and Damages
against RCBC. Meanwhile, RCBC consolidated its ownership over the property due to
LEYCON's failure to redeem the mortgaged property within the 12-month redemption
period. By virtue thereof, RCBC demanded rental payments from Metro Container
Corporation (METROCAN) which was leasing the mortgaged property from LEYCON.

On the other hand, LEYCON filed an action for Unlawful Detainer against METROCAN
before the MeTC. Consequently, METROCAN filed a complaint for Interpleader against
LEYCON and RCBC before the RTC to compel them to interplead and litigate their
several claims among themselves and to determine which among them shall rightfully
receive the payment of monthly rentals on the subject property.

On 31 October 1995, judgment was rendered in the Unlawful Detainer case, which,
among other things, ordered METROCAN to pay LEYCON whatever rentals due on the
subject premises. The said decision became final and executory. By reason thereof,
METROCAN and LEYCON separately filed a motion to dismiss the interpleader case.
However, the said motions were dismissed for lack of merit. METROCAN appealed to the
Court of Appeals which granted the petition and ordered the dismissal of the interpleader
case. Hence, RCBC filed the instant petition.

Issue: May METROCAN unilaterally cause the dismissal of the interpleader case?

Held: Yes. An action of interpleader is afforded to protect a person not against double
liability but against double vexation in respect of one liability. It requires, as an
indispensable requisite, that conflicting claims upon the same subject matter are or may
be made against the plaintiff-in-interpleader who claims no interest whatever in the
subject matter or an interest which in whole or in part is not disputed by the claimants.

When the decision in the Unlawful Detainer case became final and executory,
METROCAN has no other alternative left but to pay the rentals to LEYCON. Precisely
because there was already a judicial fiat to METROCAN, there was no more reason to
continue with the interpleader case. Thus, METROCAN moved for the dismissal of the
interpleader action not because it is no longer interested but because there is no more
need for it to pursue such cause of action. The decision in the Unlawful Detainer
case resolved the conflicting claims insofar as payment of rentals was concerned.

RCBC was correct in saying that it is not bound by the decision in the Unlawful Detainer
case. It is not a party thereto. However, it could not compel METROCAN to pursue the
interpleader case. RCBC has other avenues to prove its claim. It is not bereft of other
legal remedies. In fact, the issue of ownership can very well be threshed out in the case
for Nullification of Extrajudicial Foreclosure Sale and Damages filed by LEYCON against
RCBC.

2. Lim v. Continental Development Corporation, G.R. Nos. L-41818 and 41831,


February 18, 1976;

3. Sy-Quia v. Sheriff of Ilocos Sur, 46 Phi. 400 (1924);

4. Pangkalinawan v. Rodas, 80 Phil. 28 (1976);

5. United Coconut Planters Bank v. Intermediate Appellate Court, G.R. Nos. 726645-65,
20 March 1990;

6. Del Carmen v. Spouses Sabordo, G.R. No. 181723, August 11, 2014;

7. Pasricha v. Don Luis Dison Realty, Inc., G.R. No. 136409, March 14, 2008
8. Arreza v. Diaz, G.R. No. 133113, 30 August 2001;
Facts: Bliss Development Corporation is the owner of a housing complex located in
Quezon City. It instituted before RTC Makati an interpleader case against Arreza and
Diaz who were conflicting claimants of the property (Civil Case No. 94-2086). The RTC
ruled in favor of Arreza. In view of said decision, Bliss executed a contract to sell the
property to Arreza and Diaz was constrained to transfer possession together with all
improvements to Arreza.

Thereafter, Diaz filed a case against Arreza and Bliss for the reimbursement of the cost
of his acquisition and improvements on the property (Civil Case No. 96-1372). Arreza filed
a Motion to Dismiss on the ground of res judicata and lack of cause of action. RTC denied
the Motion to Dismiss.

Arreza appealed to CA which dismissed the petition saying that res judicata does not
apply because the interpleader case only settled the issue on who had a better right. It
did not determine the parties‘ respective rights and obligations. The action filed by Diaz
seeks principally the collection of damages in the form of the payments Diaz made to
Bliss and the value of the improvements he introduced on the property matters that were
not adjudicated upon in the previous case for interpleader.

Issue: Are Diaz's claims for reimbursement against Arreza barred by res adjudicata?

Held: The court in a complaint for interpleader shall determine the rights and obligations
of the parties and adjudicate their respective claims. Such rights, obligations and claims
could only be adjudicated if put forward by the aggrieved party in assertion of his rights.
That party in this case referred to respondent Diaz. The second paragraph of Section 5
of Rule 62 of the 1997 Rules of Civil Procedure provides that the parties in an interpleader
action may file counterclaims, cross-claims, third party complaints and responsive
pleadings thereto, as provided by these Rules. The second paragraph was added to
Section 5 to expressly authorize the additional pleadings and claims enumerated therein,
in the interest of a complete adjudication of the controversy and its incidents. Pursuant to
said Rules, respondent should have filed his claims against petitioner Arreza in the
interpleader action. Having asserted his rights as a buyer in good faith in his answer, and
praying relief therefor, respondent Diaz should have crystallized his demand into specific
claims for reimbursement by petitioner Arreza. This he failed to do. Having failed to set
up his claim for reimbursement, said claim of respondent Diaz being in the nature of a
compulsory counterclaim is now barred.

The elements of res adjudicata are: (a) that the former judgment must be final; (b) the
court which rendered judgment had jurisdiction over the parties and the subject matter;
(c) it must be a judgment on the merits; and (d) there must be between the first and
second causes of action identity of parties, subject matter, and cause of action. In the
present case, we find there is an identity of causes of action between Civil Case No. 94-
2086 and Civil Case No. 96-1372. Respondent Diaz's cause of action in the prior case,
now the crux of his present complaint against petitioner, was in the nature of an unpleaded
compulsory counterclaim, which is now barred. There being a former final judgment on
the merits in the prior case, rendered in Civil Case No. 94-2086 by Branch 146 of the
Regional Trial Court of Makati, which acquired jurisdiction over the same parties, the
same subject property, and the same cause of action, the present complaint of
respondent herein (Diaz) against petitioner Arreza docketed as Civil Case No. 96-1372
before the Regional Trial of Makati, Branch 59 should be dismissed on the ground of res
adjudicata.

9. Baclayon v. Court of Appeals, G.R. No. 89132, 26 February 1990;

10. Beltran v. People’s Homesite and Housing Corporation, G.R. No. L-25138, 28
August 1996;

Facts: Plaintiffs since they first occupied their housing units under lease from PHHC,
under lease and paying monthly rentals therefor, they were assured that after 5 years of
continuous occupancy they would be entitled to purchase said units. In 1991, PHHC
announced that the management of the project would be transferred to GSIS in payment
of PHHC's debts to GSIS. Subsequently, however, the new manager of PHHC refused to
recognize all transactions and undertakings previously entered into with GSIS. Alleging
that they do not know now to whom they should pay the monthly amortizations, plaintiffs
filed an interpleader suit against GSIS and PHHC.

GSIS and PHHC filed a motion to dismiss for failure to state a cause of action. After
hearing the motion, the court dismissed the interpleader case ruling that during the
hearing, the counsel for defendant ratified the allegations in his motion and made of
record that GSIS has no objection that payments on the monthly amortizations from the
residents of Project 4 be made directly to PHHC. Plaintiffs appealed, contending the
allegations in their complaint raise questions of fact that can be established only by
answer and trial on the merits and not by a motion to dismiss heard by mere oral
manifestations in open court.

Issue: Did the trial court erred in dismissing the complaint for interpleader?

Held: No. Rule 63, section 1 of the Revised Rules of Court requires as an indispensable
element that "conflicting claims upon the same subject matter are or may be made"
against the plaintiff-in-interpleader "who claims no interest whatever in the subject matter
or an interest which in whole or in part is not disputed by the claimants."

The record shows clearly that there were no conflicting claims by defendant corporations
as against plaintiff-tenants, which they may properly be compelled in an interpleader suit
to interplead and litigate among themselves. While the two defendant corporations may
have conflicting claims between themselves with regard to the management,
administration and ownership of Project 4, such conflicting claims are not against the
plaintiffs nor do they involve or affect the plaintiffs. No allegation is made in their complaint
that any corporation other than the PHHC which was the only entity privy to their lease-
purchase agreement, ever made on them any claim or demand for payment of the rentals
or amortization payments. Both defendant corporations were in conformity and had no
dispute, as pointed out by the trial court that the monthly payments and amortizations
should be made directly to the PHHC alone. Both defendant corporations were agreed
that PHHC should continue receiving the tenants' payments, and that such payments
would be duly recognized even if the GSIS should eventually take over Project 4 by virtue
of their turnover agreement.

11. Wack-Wack Golf & Country Club, Inc. v. Won, G.R. No. L-23851, 26 March 1976;
Facts: Wack Wack Golf and Country Club filed a complaint for interpleader against Won
and Tan who both claim ownership over membership fee certificate 201. Won claims its
ownership stemming from a decision rendered in Civil Case 26044 entitled "Lee E. Won
alias Ramon Lee vs. Wack Wack Golf & Country Club, Inc." Meanwhile, Tan claims
ownership from the assignment made by the alleged true owner of the same certificate.
The trial court dismissed the complaint on the ground of res judicata by reason of the
previous civil case that issued Won the right to the certificate. Hence, the appeal.

Issue: Was the remedy of interpleader proper and timely?

Held: There is no question that the subject matter of the present controversy, i.e., the
membership fee certificate 201, is proper for an interpleader suit. However, the
Corporation may not properly invoke the remedy of interpleader.

It is the general rule that before a person will be deemed to be in a position to ask for an
order of intrepleader, he must be prepared to show, among other prerequisites, that he
has not become independently liable to any of the claimants. Indeed, if a stakeholder
defends a suit filed by one of the adverse claimants and allows said suit to proceed to
final judgment against him, he cannot later on have that part of the litigation repeated in
an interpleader suit.

In the case at hand, the Corporation allowed civil case 26044 to proceed to final judgment.
It was aware of the conflicting claims of the appellees with respect to the membership fee
certificate 201 long before it filed the present interpleader suit. Yet it did not interplead
Tan. It preferred to proceed with the litigation and to defend itself therein. As a matter of
fact, final judgment was rendered against it and said judgment has already been
executed. It is therefore too late for it to invoke the remedy of interpleader

To now permit the Corporation to bring Won to court after the latter's successful
establishment of his rights in civil case 26044 to the membership fee certificate 201, is to
increase instead of to diminish the number of suits, which is one of the purposes of an
action of interpleader, with the possibility that the latter would lose the benefits of the
favorable judgment. This cannot be done because having elected to take its chances of
success in said civil case 26044, with full knowledge of all the fact, the Corporation must
submit to the consequences of defeat.

Besides, a successful litigant cannot later be impleaded by his defeated adversary in an


interpleader suit and compelled to prove his claim anew against other adverse claimants,
as that would in effect be a collateral attack upon the judgment.

In fine, the instant interpleader suit cannot prosper because the Corporation had already
been made independently liable in civil case 26044 and, therefore, its present application
for interpleader would in effect be a collateral attack upon the final judgment in the said
civil case; the appellee Lee had already established his rights to membership fee
certificate 201 in the aforesaid civil case and, therefore, this interpleader suit would
compel him to establish his rights anew, and thereby increase instead of diminish
litigations, which is one of the purposes of an interpleader suit, with the possibility that the
benefits of the final judgment in the said civil case might eventually be taken away from
him; and because the Corporation allowed itself to be sued to final judgment in the said
case, its action of interpleader was filed inexcusably late, for which reason it is barred by
laches or unreasonable delay.

12. United Coconut Planters Bank v. Intermediate Appellate Court, G.R. Nos. 726645-
65, 20 March 1990

RULE 63: DECLARATORY RELIEF AND SIMILAR REMEDIES


CIVIL CODE, Art. 1359 to 1369

CIVIL CODE, Art. 476 to 481


1. Malana, et al., v. Tappa, et al., G.R. No. 181303, 17 September 2009;
2. Valerde v. Social Justice Society, G.R. No. 159357, 28 April 2004;
3. Tambunting, Jr. v. Spouses Sumabat, G.R. No. 144101, September 16, 2005;
4. Mangahas, et al., v. Paredes, et al., G.R. No. 157866, 14 February 2007;
5. City of Lapu-Lapu v. Phil. Economic Zone Authority, G.R. No. 184203 and 187583,
26 November 2014;
6. CJH Development Corporation v. Bureau of Internal Revenue, et al., G.R. No.
172457, 24 December 2008;
7. Velarde v. Social Justice Society, G.R. No. 159357, 28 April 2004;
8. Ollada v. Central Bank of the Philippines, G.R. No. L-11357, 31 May 1962;
9. Republic v. Roque, G.R. No. 204603, 24 September 2013;
10. Tanda v. Aldaya, 98 Phil 244 (1956);
11. Philippine Deposit Insurance Corporation v. Court of Appeals, et al., G.R. No.
126911, 30 April 2003;
12. Matalin Coconut Co., v. Municipal Council of Malabang, Lanao del Sur, et al., G.R.
No. L-28138, 13 August 1986;
13. Department of Budget and Mangement, et al., v. Manila’s Finest Retirees
Association, Inc., et al., G.R. No. 169466, 9 May 2007;
14. Crisologo v. Centeno, G.R. No. 20014, 27 November 1968; Ramos v. Court of
Appeals, G.R. No. L-42108, 29 December 1989;
15. Ramos v. Court of Appeals, G.R. No. L-42108, 29 December 1989;
16. Republic v. Batuigas, G.R. No. 183110, 7 October 2013; Tan vs. Republic, G.R. No.
L-16108, 31 October 1961
RULE 64: REVIEW OF JUDGMENTS AND FINAL ORDERS OR RESOLUTIONS OF
THE COMELEC AND COA
Article IX-A, C and D of the Constitution
1. Pates v. COMELEC, G.R. No. 184915, 30 June 2009;
2. Paa v. Court of Appeals, G.R. No. 126560, 4 December 1997;
3. Lokin, Jr. v. Commission on Elections, G.R. No. 193808, 26 June 2012;
4. Fortune Life Insurance Company, Inc., v. Commission on Audit, G.R. No. 213525, 27
January 2015;
5. Osmeña v. COA, G.R. No. 188818, May 31, 2011
6. Pormento v. Estrada, et al., G.R. No. 191988, 31 August 2010;

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