Vda. De Camilo v.

Arcamo
Facts:

Petitioner Petra had been in peaceful, open and adverse possession of a parcel of public foreshore
land situated in Malangas, Zamboanga del Sur. A commercial building was erected on said property and
respondent Ong Peng Kee was a lessee of one of the apartments of said commercial building. Bannister
filed an unlawful detainer case against both De Camilo and Kee but for his failure to appear at the trial, he
was declared in default. Petitioners Franciscos had also been in possession, peaceful, open and adverse
of a parcel of public foreshore land, adjoining that land occupied by De Camilo. On this parcel, a
commercial building was erected by the Franciscos. The two commercial buildings were burned down.
Two weeks thereafter, respondents Kee and Ong, constructed a building of their own which was so built
that portions of the lands previously occupied by petitioners were encroached upon.

De Camilo filed a case for Forcible Entry against the respondents with respect to portion belonging to her
wherein the building of Kee was erected. The Franciscos filed a similar case. The respondents claimed that
the land where they constructed their building was leased to them by the Municipality of Malangas.
Pending trial of the two cases, the respondents filed a complaint for Interpleader against De Camilo,
Estrada, the Franciscos, Bannister, the Mayor and Treasurer of Malangas, alleging that the filing of the
cases of forcible entry, indicated that the defendants in the Interpleader had conflicting interests, since
they all claimed to be entitled to the possession of the lot in question and they (Kee and Ong) could not
determine without hazard to themselves who of defendants was entitled to the possession. Interpleader
plaintiffs further alleged that they had no interest in the property other than as mere lessees.

Mesina filed a petition for certiorari with preliminary injunction with IAC o dismissed by IAC o MR of
Mesina also denied

TC decision on interpleader: ordered AB to replace Cashier's Check in favor of Go or its cash equivalent
with legal rate of interest from date of complaint.

Issue:

W/N interpleader suit is proper?

Held:

YES. Decision affirmed in toto.

Mesina insists that there is no showing of conflicting claims; thus, interpleader is out of the question.
However, AB merely took the necessary precaution not to make a mistake as to whom to pay and
therefore interpleader was its proper remedy. It has been shown that the interpleader suit was filed by
AB because Mesina and Go were both laying their claims on the check. Mesina was even asking payment
thereon and Go as the purchaser or owner. AB filed the interpleader suit not because petitioner sued it
but because Mesina is laying claim to the same check that Go is claiming. On the very day AB instituted
the case in interpleader, it was not aware of any suit for damages filed by Mesina against it as supported
by the fact that the interpleader case was first entitled Associated Bank vs. Jose Go and John Doe.
Wack-wack Golf vs Won

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?

Ruling:

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.

RCBC vs Metro Container Corporation

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.