Beltran, et al (plaintiffs) vs. PHHC G.R. No.
L-25138 August 28, 1969
Facts:
Plaintiffs are occupying housing units under a project of PHHC, under lease and they pay
rentals. They were assured that after 5 yrs of continuous occupancy they would be entitled to
purchase such lots. However, PHHC announced that the management of the project would be
transferred to GSIS. The manager of PHHC refused to recognize all transactions. But later on
both the GSIS and the PHHC agreed that payment of the monthly amortizations by the
residents would be made directly to the PHHC. Alleging that they do not know now where to
pay the monthly amortizations, plaintiffs filed an interpleader suit against GSIS and PHHC to
settle the ownership of the project.
Issue: WON the filing of an interpleader suit is proper.
Held: No, 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. .
An indispensable requirement of interpleader is 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.”
While the two defendant corporations may have conflicting claims between themselves with
regard to the management, administration and ownership of the Project, such conflicting claims
are not against the plaintiffs nor do they involve or affect the plaintiffs.
These conflicting claims are between the two corporations and not against plaintiffs. 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.
Wack Wack vs. Won G.R. No. L-23851 March 26, 1976
Facts:
Won claims ownership of a membership fee certificate at Wack Wack Golf & Country Club. By
virtue of a civil case, he was issued such certificate. But a certain Tan also claims ownership
over such certificate pursuant to an assignment made by the alleged true owner of the same
certificate. Thus, Wack Wack filed a complaint to interplead Won and Tan to litigate their
conflicting claims. 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.
Issue: WON Wack Wack is barred to file an interpleader suit.
Held: Yes.
As to the subject matter (Membership fee certificate), there is no question that such is proper
for an interpleader suit. However, the instant interpleader suit cannot prosper because Wack
Wack had already been made independently liable in the previous civil case wherein Won had
established his rights to the certificate and, therefore, its present application for interpleader
would in effect be a collateral attack upon the final judgment in the civil case. Being so, this
interpleader suit, if granted, would compel Won to establish his rights anew, and thereby
increase instead of diminish litigations, which is one of the purposes of an interpleader suit.
And because Wack Wack 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
