Wack Wack Golf & Country Club, Inc. v. Won, et al.

Lee E. Won and Bienvenido Tan both claimed ownership over Wack Wack Golf and Country Club's membership fee certificate 201, the former, by virtue of the decision rendered in Civil Case 26044 of the Court of First Instance of Manila and of membership fee certificate 201-serial No. 1478 issued pursuant to a court order in said case, and the latter by virtue of membership fee certificate 201-serial No. 1199 issued to him in July 1950 pursuant to an assignment made in his favor by the original owner and holder thereof. The corporation filed an action of interpleader in the court a quo to have defendants litigate among themselves their conflicting claims of ownership. In separate motions, the defendants moved to dismiss the complaint upon the grounds of res judicata, failure of the complainant to state a cause of action, and bar by prescription. Finding the first two grounds well taken, the trial court dismissed the complain. Hence, this appeal, the determinative issue of which is the timeless of the remedy of interpleader availed of by the Corporation.

The Supreme Court held that because the Corporation had allowed itself to be sued to final judgment and be made independently liable in civil case 26044 and the appellee Lee had already established in said case his rights to membership fee certificate 201, its action of interpleader is barred by laches.

Order affirmed.

Rizal Commercial Banking Corporation v. Metro Container Corporation

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 docketed as Civil Case No. 4037-V-93. 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, on 26 May 1994, LEYCON filed an action for Unlawful Detainer against METROCAN before the Metropolitan Trial Court (MeTC), Branch 82 of Valenzuela, Metro Manila, docketed as Civil Case No. 6202. Consequently, METROCAN filed a complaint for Interpleader against LEYCON and RCBC docketed as Civil Case No. 4398-V-94 before the Regional Trial Court, Branch 75 of Valenzuela 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. During the pre-trial conference of the interpleader case, the trial court ordered the dismissal of the case insofar as METROCAN and LEYCON were concerned in view of an amicable settlement they entered into. 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 in the interpleader case. However, the said two motions were dismissed for lack of merit. Thereafter, METROCAN sought relief from the Court of Appeals via a petition for certiorari and prohibition.

Thus, the Court of Appeals granted the petition and ordered the dismissal of the interpleader case. Hence, RCBC filed the instant petition.

The Court sustained the Court of Appeals. 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. The decision in Civil Case No. 6202 resolved the conflicting claims insofar as payment of rentals was concerned. Petitioner then was correct in saying that it is not bound by the decision in Civil Case No. 5202. 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. It is not bereft of other legal remedies. In fact, the 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.

Lim v. Continental Development Corporation

A complaint for interpleader was filed by Continental Development Corporation (CDC) against Benito Gervacio Tan and Zoila Co Lim, praying that said defendants be directed to interplead and litigate their respective claims over the shares of stock in its possession. CDC alleged that, since both defendants claim ownership of the shares of stock, is it not in a position to justly and correctly determine the conflicting claims; that it cannot dispose of the shares of stock as both defendants threatened to take punitive measure against it should it adopt steps the may prejudice their respective interest; and that it has no interest over the subject matter of the complaint.

The trial court dismissed the complain for lack of cause of action invoking Section 35 of the Corporation Law (Act 1459, as amended). CDC and defendant Zoila Co Lim filed their respective motions for reconsideration of the trial court's order but the same were denied, hence, these petitions for review on certiorari.

The Supreme Court held that an active conflict of interests over the shares of stock exist between the defendants, and the court a quo gravely abused its discretion in dismissing the complaint for interpleader without giving full opportunity to defendants to litigate their respective claims, which dismissal has the effect of determining the question of ownership in favor of defendant Benito Gervacio Tan.

Petition granted with costs.

Almeda , et al. v. Bathala Marketing Industries, Inc.

Facts: In May 1997, respondent Bathala Marketing Industries, Inc. (lessee) entered into a contract of lease with petitioners (lessors). Provisions of the contract of lease include: 

6th - Lessee shall pay an increased rent if there is any new tax imposed on the property 

7th - In case of supervening extraordinary inflation or devaluation of the PHP, the value of PHP at the time of the establishment of the obligation shall be the basis of payment 

Petitioners later demanded payment of VAT and 73% adjusted rentals pursuant to the foregoing provisions. Respondent refused and filed an action for declaratory relief. Petitioners filed an action for ejectment. 

Issue: Whether or not declaratory relief is proper. 

Held: YES. Petitioners insist that respondent was already in breach of the contract when the petition was filed, thus, respondent is barred from filing an action for declaratory relief. However, after petitioners demanded payment of adjusted rentals and in the months that followed, respondent complied with the terms and conditions set forth in their contract of lease by paying the rentals stipulated therein. Respondent religiously fulfilled its obligations to petitioners even during the pendency of the present suit. There is no showing that respondent committed an act constituting a breach of the subject contract of lease. Thus, respondent is not barred from instituting before the trial court the petition for declaratory relief. 

Petitioners further claim that the instant petition is not proper because a separate action for rescission, ejectment and damages had been commenced before another court; thus, the construction of the subject contractual provisions should be ventilated in the same forum. 

As a rule, the petition for declaratory relief should be dismissed in view of the pendency of a separate action for unlawful detainer. In this case, however, the trial court had not yet resolved the rescission/ejectment case during the pendency of the declaratory relief petition. In fact, the trial court, where the rescission case was on appeal, initiated the suspension of the proceedings pending the resolution of the action for declaratory relief.

Velarde v. Social Justice Society

FACTS: The Petition prayed for the resolution of the question "whether or not the act of a religious leader like any of herein respondents, in endorsing the candidacy of a candidate for elective office or in urging or requiring the members of his flock to vote for a specified candidate, is violative of the letter or spirit of the constitutional provisions .They alleged that the questioned Decision did not contain a statement of facts and a dispositive portion.

ISSUE: What is the standard form of a Decision? Did the challenge Decision comply with the aforesaid form?

RULING: The decision shall be in writing, personally and directly prepared by the judge, stating clearly and distinctly the facts and the law on which it is based, signed by the issuing magistrate, and filed with the clerk of court. In general, the essential parts of a good decision consist of the following: (1) statement of the case; (2) statement of facts; (3) issues or assignment of errors; (4) court ruling, in which each issue is, as a rule, separately considered and resolved; and, finally, (5) dispositive portion. The ponente may also opt to include an introduction or a prologue as well as an epilogue, especially in cases in which controversial or novel issues are involved.No. Counsel for SJS has utterly failed to convince the Court that there are enough factual and legal bases to resolve the paramount issue. On the other hand, the Office of the Solicitor

General has sided with petitioner insofar as there are no facts supporting the SJS Petition and the assailed Decision. The Petition failed to state directly the ultimate facts that it relied upon for its claim. During the Oral Argument, counsel for SJS candidly admitted that there were no factual allegations in its Petition for Declaratory Relief. Neither were there factual findings in the assailed Decision. At best, SJS merely asked the trial court to answer a hypothetical question. In effect, it merely sought an advisory opinion, the rendition of which was beyond the court’s constitutional mandate and jurisdiction.

Indeed, the assailed Decision was rendered in clear violation of the Constitution, because it made no findings of facts and final disposition.

Philippine Deposit Insurance Corporation v. Court of Appeals

Respondents filed claims with the Philippine Deposit Insurance Corporation (PDIC) for the payment of the twenty insured golden time deposits (GTDs) at the Manila Banking Corporation (MBC), Iloilo Branch. PDIC paid respondents the value of three claims; however, it withheld the payment of the seventeen remaining claims. Subsequently, PDIC filed a petition for declaratory relief against respondents for a judicial declaration of the insurability of respondents' GTDs. The trial court declared the GTDs of respondents to be deposit liabilities of MBC, hence, are liabilities of PDIC as statutory insurer. The Court of Appeals (CA) affirmed the decision of the trial court, except as to the award of legal interest which it deleted. Hence, this petition.

In affirming the decision of the CA, the Supreme Court ruled that PDIC is liable only for deposits received by a bank in the usual course of business. That no actual money in bills and/or coins was handed by respondents to MBC does not mean that the transactions on the new GTDs did not involve money and that there was no consideration therefor, for the outstanding balance of respondents' 71 GTDs in MBC prior to May 26, 1987 was re-deposited by respondents under 28 new GTDs, eight of which were pre-terminated and withdrawn by respondent Abad. MBC had cash on hand — more than double the outstanding balance of respondents' 71 GTDs — at the start of the banking day on May 25, 1987. Since respondent Abad was at MBC soon after it opened at 9:00 a.m. of that day, petitioner should not presume that MBC had no cash to cover the new GTDs of respondents and conclude that there was no consideration for said GTDs. Petitioner having failed to overcome the presumption that the ordinary course of business was followed, the Court found that the 28 new GTDs were deposited in the usual course of business of MBC.

Department of Budget and Management, et al. v. Manila’s Finest Retirees Association Inc.

Araneta, et al. v. Gatmaitan, et al., and Soriano v. Araneta, et al

Jumamil v. Cafe, et al.