Beruflich Dokumente
Kultur Dokumente
Bliss Development owned a housing unit located at Lot 27, Block 30, ISSUE:
New Capitol Estates, Quezon City. It filed before RTC Makati Branch
146 a complaint for interpleader in the midst of a conflict of Whether or not Diaz’s claims for reimbursement against Arreza are
ownership between Edgar Arreza and Montano Diaz, Jr. The trial barred by res adjudicata.
court ruled on the interpleader in favor of Arreza, and Bliss, in view
of that decision, made a contract to sell the property to Arreza and RULING:
Diaz was ordered to transfer possession and fruits of the property
to Arreza. Thereafter, Diaz sued Arreza, Domingo Tapay and Bliss
The court in a complaint for interpleader shall determine the rights prior case, rendered in Civil Case No. 94-2086 by Branch 146 of the
and obligations of the parties and adjudicate their respective claims. Regional Trial Court of Makati, which acquired jurisdiction over the
Such rights, obligations and claims could only be adjudicated if put same parties, the same subject property, and the same cause of
forward by the aggrieved party in assertion of his rights. That party action, the present complaint of respondent herein (Diaz) against
in this case referred to respondent Diaz. The second paragraph of petitioner Arreza docketed as Civil Case No. 96-1372 before the
Section 5 of Rule 62 of the 1997 Rules of Civil Procedure provides Regional Trial of Makati, Branch 59 should be dismissed on the
that the parties in an interpleader action may file counterclaims, ground of res adjudicata.
cross-claims, third party complaints and responsive pleadings
thereto, as provided by these Rules. The second paragraph was LEONCIA BACLAYON, et. al. vs. COURT OF APPEALS, et. al.
added to Section 5 to expressly authorize the additional pleadings G.R. No. 89132 26 February 1990
and claims enumerated therein, in the interest of a complete
adjudication of the controversy and its incidents. Pursuant to said FACTS:
Rules, respondent should have filed his claims against petitioner
Leoncia, Martin, Policarpio, Hilarion, Ireneo, Juliana and Tomas, all
Arreza in the interpleader action. Having asserted his rights as a
surnamed Baclayon; Rosendo, Felicidad and Silvestra, all surnamed
buyer in good faith in his answer, and praying relief therefor,
Abanes; and Tomasa, Leoncia, Anacleto, Monica, Guillerma and
respondent Diaz should have crystallized his demand into specific
Gertrudes all surnamed Abellare filed with the then CFI-Cebu,
claims for reimbursement by petitioner Arreza. This he failed to
Branch 2, in Civil Case No. R-11185, a complaint for recovery of
do. Having failed to set up his claim for reimbursement, said claim
ownership and possession, and damages, against spouses Marciano
of respondent Diaz being in the nature of a compulsory
Bacalso and Gregoria Sabandeja of Lot No. 5528 of the Cebu
counterclaim is now barred. Elements of res judicata: (1) the former
Cadastre. The trial court ruled in favor of spouses Bacalso, declaring
judgment must be final; (b) the court which rendered judgment had
them owners of the subject lot, which decision was appealed to the
jurisdiction over the parties and the subject matter; (c) it must be a
Court of Appeals. CA reversed the trial court’s decision holding that
judgment on the merits; and (d) there must be between the first
the heirs of the late Matias Baclayaon owned the land at bar. The
and second causes of action identity of parties, subject matter, and
decision in favor of the petitioners having become final and
cause of action. In the present case, we find there is an identity of
executory, they filed a motion for execution of judgment and
causes of action between Civil Case No. 94-2086 and Civil Case No.
possession which was opposed by the private respondents. The
96-1372. Respondent Diaz's cause of action in the prior case, now
private respondents argued that since they were builders in good
the crux of his present complaint against petitioner, was in the
faith, they were entitled to the reimbursement of the necessary and
nature of an unpleaded compulsory counterclaim, which is now
useful expenses incurred from the owner of the land. The presiding
barred. There being a former final judgment on the merits in the
judge of RTC Cebu Branch 15, Hon. German Lee, granted the motion action or defenses. A corollary question that We might as well
for execution and ordered the judgment to be executed. Private resolve now (although not raised as an issue in the present petition,
respondents appealed the said order but it was dismissed by Lee. but conformably with Gayos, et al. v. Gayos, et al., G.R. No. L-27812,
Later, private respondents filed a petition for certiorari, mandamus September 26, 1975, 67 SCRA 146, that it is a cherished rule of
and prohibition with CA concerning the orders of the RTC Cebu procedure that a court should always strive to settle the entire
which was granted by respondent court, thereby setting aside the controversy in a single proceeding leaving no root or branch to bear
trial court’s orders and ordering the same court to hear respondents’ the seeds of future litigation) is whether or not the private
evidence that they were builders in good faith. respondents can still file a separate complaint against the
petitioners on the ground that they are builders in good faith and
RULING: consequently, recover the value of the improvements introduced by
The rule is well established that once a decision has become final them on the subject lot. The case of Heirs of Laureano Marquez v.
and executory the only jurisdiction left with the trial court is to Valencia, 99 Phil. 740, provides the answer: "If, aside from relying
order its execution. To require now the trial court in a hearing solely on the deed of sale with a right to repurchase and failure on
supplementary to execution, to receive private respondents' the part of the vendors to purchase it within the period stipulated
evidence to prove that they are builders in good faith of the therein, the defendant had set up an alternative though
improvements and the value of said improvements, is to disturb a inconsistent defense that he had inherited the parcel of land from
final executory decision; which may even cause its substantial his late maternal grandfather and presented evidence in support of
amendment. It appears that the private respondent's opposition to both defenses, the overruling of the first would not bar the
the motion for the execution of the judgment, possession and determination by the court of the second. The defendant having
demolition is their last straw to prevent the satisfaction of the failed to set up such alternative defenses and chosen or elected to
judgment. Sad to say, we have to cut this straw. We disagree with rely on one only, the overruling thereof was a complete
the respondent court that any counterclaim for reimbursement of determination of the controversy between the parties which bars a
the value of the improvements thereon by reason of private subsequent action based upon an unpleaded defense, or any other
respondents' being builders in good faith, which presupposes that cause of action, except that of failure of the complaint to state a
they are not the owners of the land, would run counter to the cause of action and of lack of jurisdiction of the Court. The
defense of ownership and therefore could not have been set up determination of the issue joined by the parties constitutes res
before the trial court. It should be emphasized that Rule 8, Section 2 judicata."
of the Rules of Court allows a party to set forth two or more
statements of a claim or defense alternatively or hypothetically,
either in one cause of action or defense or in separate causes of
through its new Chairman-General Manager, Esmeraldo Eco,
refused to recognize agreements previously entered into with GSIS,
while GSIS insisted on its legal rights to enforce the said agreements
and was upheld in its contention by both the Government
Corporate Counsel and the Secretary of Justice. Plaintiffs thus
JOSE BELTRAN vs. PEOPLE’S HOMESITE & HOUSING CORPORATION claimed that these conflicting claims between PHHC and GSIS
caused them great inconvenience and incalculable moral and
G.R. No. L-25138 28 August 1969
material damage, as they did not know to whom they should pay
FACTS: the monthly amortizations or payments.
In 1962, an interpleader suit was commenced by Jose Beltran, et. al. TC: Designated the People's First Savings Bank, QC "to receive in
in their own behalf and in behalf of the residents of Project 4 in trust the payments from the plaintiffs on their monthly
Quezon City, praying that the People’s Homesite & Housing amortizations on PHHC lots and to be released only upon proper
Corporation and Government Service Insurance System be authority of the Court."
compelled to litigate between themselves their conflicting claims
PHHC and GSIS filed a Motion to Dismiss the complaint of Beltran,
over Project 4. PHHC leased out housing units to plaintiffs in 1953.
et al. for failure to state a cause of action as well as to lift the
The lessees, paying monthly rentals therefor, were assured by
Court's order designating the People's First Savings Bank as trustee
competent authority that after 5 years of continuous occupancy,
to receive the tenants' payments on the PHHC lots. TC granted the
they would be entitled to purchase these units. In 1961, the PHHC
Motion, ruling that the counsel for GSIS ratified the allegations in his
announced that the management, administration and ownership
motion and made of record that GSIS has no objection that
of Project 4 would be transferred to GSIS in payment of PHHS debts
payments on the monthly amortizations be made directly to PHHC.
to GSIS. PHHC also asked the tenants to signify their conformity to
There was thus no dispute as to whom the residents pay and
buy the housing units at the selling price indicated on the back
therefore no cause of action for interpleading. Counsel for
thereof, agreeing to credit the tenants, as down payment on the
defendants went further to say that whatever dispute, if any, may
selling price, 30% of what had been paid by them as rentals. The
exist between the two corporations over the lots and
tenants accepted the PHHC offer, and on March 27, 1961, the PHHC
buildings in Project 4, payments made to the PHHC will
announced in another circular that all payments made by the
not and cannot in any way affect or prejudice the rights
tenants after March 31, 1961 would be considered as amortizations
of the residents thereof as they will be credited by either of the
or installment payments. By the end of 1960, administration and
two defendants.
ownership of Project 4 was turned over to GSIS. PHHC, however,
On appeal, plaintiffs claim that the trial Court erred in dismissing complaint concerning the enforceability, and recognition or non-
their suit, contending the allegations in their complaint "raise enforceability and non-recognition of the turnover agreement of
questions of fact that can be established only by answer and trial on December 27, 1961 between the two defendant corporations are
the merits and not by a motion to dismiss heard by mere oral irrelevant to their action of interpleader, for these conflicting claims,
manifestations in open court," and that they "do not know who, as loosely so-called, are between the two corporations and not against
between the GSIS and the PHHC, is the right and lawful party plaintiffs. Both defendant corporations were in conformity and had
to receive their monthly amortizations as would eventually no dispute, as pointed out by the trial court that the monthly
entitle them to a clear title to their dwelling units." payments and amortizations should be made directly to the PHHC
alone.
ISSUE:
WACK WACK GOLF & COUNTRY CLUB vs. LEE WON
Whether the dismissal of the complaint for interpleader was
proper? G.R. No. L-23851 26 March 1976
RULING: FACTS:
Yes. Plaintiffs entirely missed the vital element of an action of Wack Wack Golf & Country Club, a non-stock, civic and athletic
interpleader. Rule 62, section 1 of the Revised Rules of Court corporation organized under the laws of the Philippines, filed a
requires as an indispensable element that "conflicting claims upon complaint of interpleader. It alleged, for its first cause of action,
the same subject matter are or may be made" against the plaintiff- that defendants Lee Won and Bienvenido Tan were both claiming
in-interpleader "who claims no interest whatever in the subject ownership over the Corporation’s membership fee certificate
matter or an interest which in whole or in part is not disputed by (“MFC”) 201: Won, by virtue of the decision of the CFI of Manila in
the claimants." civil case 26044 and by MFC 201-serial no. 1478 issued on Oct. 17,
1963 by the deputy clerk of court for and in behalf of the president
While PHHC and GSIS may have conflicting claims between and secretary of the corporation and of the People’s Bank & Trust
themselves with regard to the management, administration and
Company; Tan, on the other hand, by virtue of MFC 201-serial no.
ownership of Project 4, such conflicting claims are not against the 1199 issued on July 24, 1950 pursuant to an assignment in his favor
plaintiffs nor do they involve or affect the plaintiffs. No allegation is by Swan, Culbertson and Fritz, the original owner of MFC 201. For
made in their complaint that any corporation other than the PHHC
its second cause of action, the Corporation alleged that MFC 201-
which was the only entity privy to their lease-purchase agreement, serial no. 1478 issued by the deputy clerk of court in behalf of the
ever made on them any claim or demand for payment of the rentals Corporation is null and void because it was issued in violation of the
or amortization payments. The questions of fact raised in their
Corporation’s by-laws, which require the surrender and cancellation reasonable diligence to hale the contending claimants to court. He
of the outstanding MFC 201 before issuance may be made to the need not await actual institution of independent suits against him
transferee of a new certificate duly signed by its president and before filing a bill of interpleader. He should file an action of
secretary, aside from the fact that the decision of the CFI of Manila interpleader within a reasonable time after a dispute has arisen
in civil case 26044 is not binding upon defendant Tan. The without waiting to be sued by either of the contending claimants.
Corporation prayed for the issuance of an order requiring Lee and Otherwise, he may be barred by laches or undue delay. But where
Tan to interplead and litigate their conflicting claims, declaring who he acts with reasonable diligence in view of the environmental
the lawful owner of MFC 201 is, and ordering the surrender and circumstances, the remedy is not barred. If a stakeholder defends a
cancellation of MFC 201-serial no. 1478 issued in the name of Lee. suit filed by one of the adverse claimants and allows said suit to
The trial court dismissed the complaint upon motion of the proceed to final judgment against him, he cannot later on have that
defendants on the grounds of res judicata, failure of the complaint part of the litigation repeated in an interpleader suit. In the case at
to state a cause of action, and bar by prescription. hand, the Corporation allowed civil case 26044 to proceed to final
judgment. And it offered no satisfactory explanation for its failure to
ISSUE: implead Tan in the same litigation. In this factual situation, it is clear
Whether or not the action of interpleader was proper and timely that this interpleader suit cannot prosper because it was filed much
filed. too late. A successful litigant cannot later be impleaded by his
defeated adversary in an interpleader suit and compelled to prove
HELD: his claim anew against other adverse claimants, as that would in
effect be a collateral attack upon the judgment. In fine, the
No. The Supreme Court affirmed the dismissal of the complaint. The
interpleader suit cannot prosper because the Corporation had
action of interpleader, under §120 of the Code of Civil Procedure, is
already been made independently liable in civil case 26044 and,
a remedy whereby a person who has personal property in his
therefore, its application for interpleader would in effect be a
possession, or an obligation to render wholly or partially, without
collateral attack upon the final judgment in the said civil case; Lee
claiming any right to either, comes to court and asks that the
had already established his rights to MFC 201 in the civil case and,
persons who claim the said personal property or who consider
therefore, this interpleader suit would compel him to establish his
themselves entitled to demand compliance with the obligation, be
rights anew, and thereby increase instead of diminish litigations,
required to litigate among themselves in order to determine finally
which is one of the purposes of an interpleader suit, with the
who is entitled to tone or the one thing. The remedy is afforded to
possibility that the benefits of the final judgment in the said civil
protect a person not against double liability but against double
case might eventually be taken away from him; and because the
vexation in respect of one liability. A stakeholder should use
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.