Interpleader Cases
Interpleader Cases
Interpleader Cases
By reason
September 2001 thereof, METROCAN and LEYCON separately filed
motions to dismiss the interpleader case. However,
FACTS: said motions were dismissed for lack of merit.
In 1990, Ley Construction Corporation contracted a METROCAN went to the Court of Appeals seeking relief
loan from Rizal Commercial Banking Corporation in the via a petition for certiorari and prohibition with prayer
amount of P30 million with a real estate mortgage over for issuance of TRO and preliminary injunction. In
property in Valenzuela secured. LEYCON failed to settle 1996, CA ruled in favor of METROCAN and ordered the
its obligation to pay back the loan thereby prompting dismissal of the interpleader case.
RCBC to foreclose the mortgage with the latter being ISSUE:
the highest bidder in 1992. LEYCON promptly filed an
action for Nullification of Extrajudicial Foreclosure Sale May METROCAN unilaterally have the interpleader
and Damages against RCBC. The case was raffled to case dismissed?
the Regional Trial Court (RTC) of Valenzuela, Branch
172. Meanwhile, RCBC consolidated its ownership over RULING:
the property due to LEYCONs failure to redeem it Yes. An action for interpleader is afforded to protect a
within the 12-month redemption period and a new TCT person not against double liability but against double
was issued if favor of the bank. By virtue thereof, RCBC vexation in respect of one liability. It requires that
demanded rental payments from Metro Container conflicting claims upon the same subject matter are or
Corporation (METROCAN) which was leasing the may be made against the plaintiff-in-interpleader who
property from LEYCON. In 1994, LEYCON filed an action claims no interest whatever in the subject matter or an
for Unlawful Detainer against RCBC before MeTC interest which in whole or in part is not disputed by the
Valenzuela Branch 82. METROCAN filed later a claimants. When the decision in the Unlawful Detainer
complaint for Interpleader before RTC Valenzuela case became final and executory, METROCAN had no
Branch 75 against LEYCON and RCBC to compel them other alternative left but to pay rentals to LEYCON.
to interplead their claims between themselves and to Precisely because there was a judicial fiat to
determine which of them shall rightfully receive the METROCAN, there was no more reason to continue
payment rentals on the subject property. In 1995, with the interpleader case. Thus, METROCAN moved
judgment was rendered in the Unlawful Detainer case, for the dismissal of the interpleader action not
which ordered METROCAN to pay LEYCON whatever because it was no longer interested but because there
rentals were due on the subject land. Said MeTC was no more need to pursue the action. The Unlawful
Detainer case resolved the conflicting claims insofar as that both defendants threatened to take punitive
payment of rentals was concerned. RCBC correctly measures against CDC should it take any step that
contended that it was not bound by the decision in the shall prejudice their interests; that plaintiff was not
Unlawful Detainer case as it was not a party thereto. sufficiently informed of the rights of the respective
However, it could not compel METROCAN to pursue the claimants and therefore not in a sufficient position to
Interpleader case. RCBC has other avenues to prove its adjudicate their claims; that CDC has no interest of
claim. any kind of stock and was willing to issue certificates
of stock to the claimants; and prayed that defendants
be directed to interplead between themselves their
respective claims over the said shares of stock and
determine which truly belong to them. CFI Manila
LIM vs. COMMERCIAL DEVELOPMENT Branch XXVI dismissed the complaint for lack of cause
CORPORATION of action invoking Sec. 35 of Act No. 1459 (Corporation
Law). Lim and CDC filed their respective motions for
G.R. No. L-41818; G.R. No. L-41831 18 February reconsideration of the order to which Tan filed his
1976 rejoinder. Said motions were denied in 1974.
FACTS: RULING:
In 1973, Continental Development Corporation filed a The interpleader must be granted. It is patent from the
complaint for interpleader against Benito Gervasio Tan pleadings in the lower court that both Tan and Lim
and Zoila Co Lim alleging that: in plaintiffs books, assert conflicting rights to the questioned shares of
Tans name appears as one of its stockholders in 1957 stock. Precisely in his motion to dismiss the complaint
with 50 common shares, and subsequently credited for interpleader, Tan states that petitioner corporation,
with 75 shares by way of dividends, or an outstanding through its Vice-President, notified him on July 23,
total of 125 shares of par value of P250 each; that Tan 1973 "that the shares of stock are in the possession of
had since December 1972 been demanding CDC to its treasurer Mr. Ty Lim, and urged defendant to
release the certificates of stock but which plaintiff had directly obtain them from the former, who allegedly
not done so far and was prevented from doing so was on vacation at the time. Mr. Ty Lim, on August 30,
because of Lims adverse claims; that Lim laid claim on 1973, through counsel, replied to Tan that said
the very same shares of stock being demanded by Tan, certificates were not in his possession but surmised,
alleging that the same belonged to her late mother; without reference to any record, that the same might
have been delivered to the deceased So Bi. the claimants, he may bring an action against the
Continental Development Corporation expressly stated conflicting claimants to compel them to interplead and
in the complaint that both defendants, through their litigate their several claims among themselves." This
respective lawyers, threatened to take punitive provision only requires as an indispensable requisite:
measures against it should it adopt any steps that may "that conflicting claims upon the same subject matter
prejudice their respective interests in the shares of are or may be made against the plaintiff-in-
stock in question; and that it is not sufficiently interpleader who claims no interest whatever in the
informed of the rights of the respective claimants and subject matter or an interest which in whole or in part
therefore not in a position to determine justly and is not disputed by the claimants." Indeed, CDC is
correctly their conflicting claims. And in its placed in the same situation as a lessee who does not
opposition to the motion to dismiss its complaint, know the person to whom he will pay the rentals due
petitioner Continental Development Corporation to the conflicting claims over tine property leased, or a
stressed that it might be liable to one defendant sheriff who finds himself puzzled by conflicting claims
should it comply with the demands of the other with to a property seized by him. In these examples, the
respect to the transfer or entry of the shares of stock lessee (Pangkalinawan v. Rodas, 80 Phil. 28) and the
in the books of the corporation. Since there is an sheriff (Sy-Quia v. Sheriff, 46 Phil. 400) were each
active conflict of interests between the two allowed to file a complaint in interpleader to determine
defendants, now herein respondent Benito Gervasio the respective rights of the claimants.
Tan and petitioner Zoila Co Lim, over the disputed
shares of stock, the trial court gravely abused its
discretion in dismissing the complaint for interpleader, GREGORIO SYQUIA vs. SHERIFF OF ILOCOS SUR
which practically decided ownership of the shares of
stock in favor of defendant Benito Gervasio Tan. The G.R. No. L-22807 10 October 1924
two defendants should be given full opportunity to
litigate their respective claims. Rule 63, Section 1 of FACTS:
the New Rules of Court tells us when a cause of action
In 1915, Miguel Aglipay Cheng-Laco and Feliciano
exists to support a complaint in interpleader:
Reyes Cheng-Kiangco executed a chattel mortgage in
"Whenever conflicting claims upon the same subject
favor of Gregorio Syquia on their mercantile
matter are or may be made against a person, who
establishment as a security for a debt of P6,000. The
claims no interest whatever in the subject matter, or
chattel mortgage was duly registered and due date fell
an interest which in whole or in part is not disputed by
two years later. From its terms, it was the parties
intention that the mortgagors were to be permitted to hold him harmless in such an event. In these
sell their merchandise replenishing their stock from circumstances, his action in suspending the sale
time to time and that the new stock shall also be pending the determination of the action of interpleader
subject to the mortgage. In 1924, Cheng-Laco seems justified. We may say further that in cases such
executed another chattel mortgage over the same as the present, the petition for mandamus should be
establishment in favor of Filadelfo de Leon. After the addressed to the Courts of First Instance rather than to
second mortgage was registered, Syquia requested the this court.
sheriff to take possession of the mortgaged property to
sell it at public auction under the Chattel Mortgage ALFONSO PAGKALINAWAN vs. SOTERO RODAS
Law. The sheriff then seized the property in question G.R. No. L- 1806
but de Leon presented an adverse claim to the 25 February 1948
property stating that by virtue of the second chattel
mortgage, Syquias was no longer effective. In doubt FACTS:
as to the priority of the claims, the sheriff suspended
the proceedings and brought an action for In an ejectment suit between Manuel Tambunting and
interpleader. Thereupon, the present proceeding in Alfonso and Manuel Pagkalinawan, the latter appealed
mandamus was instituted, the petitioner alleging that from the lower court to CFI Manila. The appellate court
the duty of the sheriff to proceed with the sale was a then rendered a decision sentencing the
ministerial one and praying that the sheriff be Pagkalinawans to vacate the house in question and
commanded to proceed. pay rentals due to Tambunting from November 1946 at
P45 per month plus costs. Acting upon a motion for
RULING: reconsideration filed by the Pagkalinawans, CFI
granted the motion and absolved them from the
Though it perhaps, would have been better practice for complaint. On motion from Tambunting, the same
the sheriff to sell the property and hold the proceeds of court reversed the Pagkalinawans motion and ordered
the sale subject to the outcome of the action of the latter to pay the rent for the property in question.
interpleader, we, nevertheless, are of the opinion that Defendants, however, moved to stay execution of the
the facts shown do not justify our interference by new judgment on the ground that they had filed with
mandamus. The sheriff might lay himself open to an the same court an interpleader suit against plaintiff
action for damages if he sold the goods without the and Angel de Leon Ong, praying that the latter two be
consent of the holder of the last mortgage, and it does ordered to litigate their conflicting claims over rentals
not appear that the petitioner offered to give bond to due from the defendants. CFI acceded to the motion
but did not stop the execution of its judgment. Failing Tambunting from the property located at Nos. 329 to
to obtain a reconsideration of the latter order, the 339 Tanduay Street, Manila, which includes the
defendants instituted the present petition for certiorari premises held by the petitioners. Under the law, the
and prohibition, seeking from us an order directing latter have a right to file the interpleader suit in view
Hon. Sotero Rodas, Judge of the Court of First Instance of the claim for rentals of Angel de Leon Ong; and if
of Manila, and Joaquin Garcia, sheriff, to desist from the respondent Tambunting believes that he is legally
carrying out the writ of execution. entitled to said rentals, he is free to move for the
withdrawal of the deposits made by the petitioners.
RULING:
PHHC and GSIS filed a Motion to Dismiss the complaint Whether the dismissal of the complaint for
of Beltran, et al. for failure to state a cause of action as interpleader was proper?
well as to lift the Court's order designating the People's
First Savings Bank as trustee to receive the tenants' RULING:
payments on the PHHC lots. TC granted the Motion, Yes. Plaintiffs entirely missed the vital element of an
ruling that the counsel for GSIS ratified the allegations action of interpleader. Rule 62, section 1 of the Revised
in his motion and made of record that GSIS has no Rules of Court requires as an indispensable element
objection that payments on the monthly amortizations that "conflicting claims upon the same subject matter
be made directly to PHHC. There was thus no dispute are or may be made" against the plaintiff-in-
as to whom the residents pay and therefore no cause interpleader "who claims no interest whatever in the
of action for interpleading. Counsel for defendants subject matter or an interest which in whole or in part
went further to say that whatever dispute, if any, is not disputed by the claimants."
may exist between the two corporations over
the lots and buildings in Project 4, payments While PHHC and GSIS may have conflicting claims
made to the PHHC will not and cannot in any between themselves with regard to the management,
way affect or prejudice the rights of the administration and ownership of Project 4, such
residents thereof as they will be credited by either of conflicting claims are not against the plaintiffs nor do
the two defendants. they involve or affect the plaintiffs. No allegation is
made in their complaint that any corporation other
On appeal, plaintiffs claim that the trial Court erred in than the PHHC which was the only entity privy to their
dismissing their suit, contending the allegations in lease-purchase agreement, ever made on them any
their complaint "raise questions of fact that can be claim or demand for payment of the rentals or
established only by answer and trial on the merits and amortization payments. The questions of fact raised in
their complaint concerning the enforceability, and Culbertson and Fritz, the original owner of MFC 201.
recognition or non-enforceability and non-recognition For its second cause of action, the Corporation alleged
of the turnover agreement of December 27, 1961 that MFC 201-serial no. 1478 issued by the deputy
between the two defendant corporations are irrelevant clerk of court in behalf of the Corporation is null and
to their action of interpleader, for these conflicting void because it was issued in violation of the
claims, loosely so-called, are between the two Corporations by-laws, which require the surrender and
corporations and not against plaintiffs. Both defendant cancellation of the outstanding MFC 201 before
corporations were in conformity and had no dispute, as issuance may be made to the transferee of a new
pointed out by the trial court that the monthly certificate duly signed by its president and secretary,
payments and amortizations should be made directly aside from the fact that the decision of the CFI of
to the PHHC alone. Manila in civil case 26044 is not binding upon
defendant Tan. The Corporation prayed for the
WACK WACK GOLF & COUNTRY CLUB vs. LEE issuance of an order requiring Lee and Tan to
WON interplead and litigate their conflicting claims,
G.R. No. L-23851 26 March 1976 declaring who the lawful owner of MFC 201 is, and
ordering the surrender and cancellation of MFC 201-
FACTS: serial no. 1478 issued in the name of Lee. The trial
court dismissed the complaint upon motion of the
Wack Wack Golf & Country Club, a non-stock, civic and defendants on the grounds of res judicata, failure of
athletic corporation organized under the laws of the the complaint to state a cause of action, and bar by
Philippines, filed a complaint of interpleader. It prescription.
alleged, for its first cause of action, that defendants
Lee Won and Bienvenido Tan were both claiming ISSUE:
ownership over the Corporations membership fee
certificate (MFC) 201: Won, by virtue of the decision Whether or not the action of interpleader was proper
of the CFI of Manila in civil case 26044 and by MFC and timely filed.
201-serial no. 1478 issued on Oct. 17, 1963 by the HELD:
deputy clerk of court for and in behalf of the president
and secretary of the corporation and of the Peoples No. The Supreme Court affirmed the dismissal of the
Bank & Trust Company; Tan, on the other hand, by complaint. The action of interpleader, under 120 of
virtue of MFC 201-serial no. 1199 issued on July 24, the Code of Civil Procedure, is a remedy whereby a
1950 pursuant to an assignment in his favor by Swan, person who has personal property in his possession, or
an obligation to render wholly or partially, without situation, it is clear that this interpleader suit cannot
claiming any right to either, comes to court and asks prosper because it was filed much too late. A
that the persons who claim the said personal property successful litigant cannot later be impleaded by his
or who consider themselves entitled to demand defeated adversary in an interpleader suit and
compliance with the obligation, be required to litigate compelled to prove his claim anew against other
among themselves in order to determine finally who is adverse claimants, as that would in effect be a
entitled to tone or the one thing. The remedy is collateral attack upon the judgment. In fine, the
afforded to protect a person not against double liability interpleader suit cannot prosper because the
but against double vexation in respect of one liability. Corporation had already been made independently
A stakeholder should use reasonable diligence to hale liable in civil case 26044 and, therefore, its application
the contending claimants to court. He need not await for interpleader would in effect be a collateral attack
actual institution of independent suits against him upon the final judgment in the said civil case; Lee had
before filing a bill of interpleader. He should file an already established his rights to MFC 201 in the civil
action of interpleader within a reasonable time after a case and, therefore, this interpleader suit would
dispute has arisen without waiting to be sued by compel him to establish his rights anew, and thereby
either of the contending claimants. Otherwise, he increase instead of diminish litigations, which is one of
may be barred by laches or undue delay. But where he the purposes of an interpleader suit, with the
acts with reasonable diligence in view of the possibility that the benefits of the final judgment in the
environmental circumstances, the remedy is not said civil case might eventually be taken away from
barred. If a stakeholder defends a suit filed by one of him; and because the Corporation allowed itself to
the adverse claimants and allows said suit to proceed be sued to final judgment in the said case, its
to final judgment against him, he cannot later on have action of interpleader was filed inexcusably late, for
that part of the litigation repeated in an interpleader which reason it is barred by laches or unreasonable
suit. In the case at hand, the Corporation allowed civil delay.
case 26044 to proceed to final judgment. And it
offered no satisfactory explanation for its failure to
implead Tan in the same litigation. In this factual