R62 Ocampo v TironaLessees course to interpleader

Facts:1. Petitioner Ocampo allegedly bought the subject property from one Rosauro Breton, and Respondent Tirona is a lessee occupying a portion of that property.2. When Ocampo bought the property, he gave Tirona a formal notice, duly received by Tirona. In recognition of this, Tirona paid rent to Ocampo.3. Later, Ocampo received a letter from Callejo Law (who represents Tirona) saying that Tirona is invoking her right to first refusal given that the property in question is declared as an area of priority development by PDs 1517, 1893, 1968. Tirona says that she will stop paying rental unless the NHA clears Ocampo of the dues that comes with the law provided.4. Ocampo sent a letter to Callejo Law demanding Tirona to pay rent in arrears and to vacate the premises. Despite receipt of such letter, Tirona refused Ocampos demands.5. Ocampo filed a complaint for unlawful detainer and damages against Tirona before the MTC.a. Tirona Answers:i. A certain Doa Lourdes Rodriguez Yaneza actually owns the land and Doas assignor, a certain Edison, is the general overseer of it.ii. That Ocampos title is overlapped with that of the assignoriii. That she denies and discontinues obligation to Ocampo because he is not the owner thereof.b. Ocampo moved to strike the Answer because it was not verified. Tirona moved to amend her answer, saying the first one is not verified because it wasnt assisted by counsel so she could file it on time. MTC granted amended answer.c. MTC ruled IFO Ocampod. Ocampo filed execution pending appeal, and Tirona filed notice of appeal a day later. MTC ordered the transmission of records as well as the motion for execution.e. A certain Maria Lourdes Breton-Mendiola claiming to be the owner of the subject property filed a motion to file intervention before the RTC6. RTC: Ruled IFO Ocampo.a. RTC issued writ of execution (Tirona failed to pay supersedeas bond), denied Breton-Mendiolas intervention.b. Ocampo filed memorandum:i. Tironas assertion of preferential right of first refusal is a recognition of the sale by Rosaulo Breton to himii. Tirona is no longer qualified to claim such right because she is no longer a legitimate tenantc. Tirona filed manifestation saying she paid the supersedeas bond and renti. RTC considered this as an MR to the granting of the writ of execution pending appeal, and eventually cancelled the writd. Tirona filed her memorandum:i. For the first time, Tirona said that Alipio Breton, father of Rosauro Breton, is the registered owner of the land and has been her landlord since 1962.ii. Rosauros sister, Maria Lourdes Breton-Mendiola, co-owned the property when Alipio died. Rosauro executed a deed of conveyance of the subject property and waiver in favor of Lourdes. Thus, Rosauro could not have transferred ownership to Ocampo.iii. Tirona said that she never stopped paying rent to Lourdes.e. RTC said that MTC should be upheld.7. CA: ruled IFO Tirona8. Hence, this petition

Issue: When is interpleader proper?

Held:First, on the issue of unlawful detainer (as it is related)Tirona initially argued that the true owner is a certain Doa Lourdes Yaneza before the MTC, but changed it in the RTC that it is Lourdes Breton-Mendiola. She justified the change by saying it wasnt assisted by counsel so she could file it on time, yet she initially communicated with Ocampo through Calleja Law. Tirona asserts that there is no violation of the lease agreement because she paid rent to the real owner.

Contrary to her beliefs, the issue of ownership is not essential in an unlawful detainer case. The fact of lease and its expiration are the only ones crucial. The issue of ownership cannot be assailed collaterally.

Tirona need not wait for Ocampo to file a suit against her before filing a bill of interpleader.An action for interpleader is proper when the lessee does not know the person to whom to pay rentals due to conflicting claims on the property. The court defined it as:

The action of interpleader is a remedy whereby a person who has property whether personal or real, in his possession, or an obligation to render wholly or partially, without claiming any right in both, or claims an interest which in whole or in part is not disputed by the conflicting claimants, comes to court and asks that the persons who claim the said property or who consider themselves entitled to demand compliance with the obligation, be required to litigate among themselves, in order to determine finally who is entitled to one or the other thing. The remedy is afforded not to protect a person against a double liability but to protect him against a double vexation in respect of one liability. When the court orders that the claimants litigate among themselves, there arises in reality a new action and the former are styled interpleaders, and in such a case the pleading which initiates the action is called a complaint of interpleader and not a cross-complaint

In other words, an interpleader is proper when you possess a property or has an obligation, and multiple persons is claiming ownership over it or is claiming entitlement to demand from the obligation. This remedy is afforded not to protect a person against double liability but to protect him against double vexation.

An interpleader would require conflicting claimants to litigate among themselves to determine kung sino ba talaga ang bossing. When the court orders the claimants to litigate among themselves, there is a new action. The pleading which initiated this action is called a Complaint of Interpleader and not a cross-complaint.

WHEREFORE, petition GRANTED. MTC order REINSTATED. Judgment IFO Ocampo