INTERPLEADER

Rizal Commercial Banking Corporation (RCBC) v. Metro Container Corporation, G.R. No.
127913, September 13, 2001
First Division, Justice Kapunan
Requisites

FACTS: Ley Construction Corporation (LEYCON) owns a property covered by TCT No. V-
17223. Moreover, this same property is leased by LEYCON to respondent Metro Container
Corporation (METROCAN).

Sometime in 1990, LEYCON contracted a loan from petitioner RCBC secured by a REM over
the property covered by the above TCT. When eventually LEYCON failed to pay its obligation
to RCBC, the latter instituted an extrajudicial foreclosure proceeding against the former. Later,
RCBC emerged as the highest bidder in the foreclosure sale and the title to the mortgaged
property was consolidated in favor of RCBC when LEYCON failed to redeem the same. Later,
TCT No. V-332432 was issued in favor of RCBC.

Because of this consolidation, RCBC demanded rental payments from METROCAN, as lessee in
the subject property. To make matters confusing for METROCAN, an unlawful detainer case
was instituted against it by LEYCON in May 1994 before the MeTC.

Thereafter, on May 27, 1994, METROCAN filed a Complaint for Interpleader before the RTC
against LEYCON and RCBC 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.

Eventually, however, the MeTC rendered its Decision in the unlawful detainer case ordering
METROCAN to pay LEYCON whatever rentals due on the subject property. This Decision
became final and executory.

Thereafter, METROCAN moved for the dismissal of the Interpleader case for having become
moot and academic due, among others, to the MeTC Decision in the unlawful detainer case.
LEYCON likewise moved for the dismissal of the same.

However, the RTC denied the motions for lack of merit. METROCAN and LEYCON moved for
reconsideration to no avail. Later, METROCAN elevated the matter on a petition for certiorari
and prohibition before the CA which granted the same. The CA then ordered that the
Interpleader case be dismissed. Petitioner moved for reconsideration but was denied for lack of
merit. Hence, this petition.

ISSUE: Whether the Interpleader case became moot and academic.

HELD: Yes. The Supreme Court ruled in this wise:

“In the case before us, it is undisputed that METROCAN filed the interpleader action x x x
because it was unsure which between LEYCON and RCBC was entitled to receive the payment
of monthly rentals on the subject property. LEYCON was claiming payment of the rentals as
lessor of the property while RCBC was making a demand by virtue of the consolidation of the
title of the property in its name.

It is also undisputed that LEYCON, as lessor of the subject property filed an action for unlawful
detainer x x x against its lessee METROCAN. The issue in [said case] is limited to the question
of physical or material possession of the premises.

Hence, the reason for the interpleader action ceased when the MeTC rendered judgment in [the
unlawful detainer case] whereby the court directed METROCAN to pay LEYCON "whatever
rentals due on the subject premises x x x." When the decision in [said 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.

It should be remembered that 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 [the
unlawful detainer case] resolved the conflicting claims insofar as payment of rentals was
concerned.”

WHEREFORE, the petition for review is DENIED.

Ramos, et al v. Ramos, et al., G.R. No. 144294, May 11, 2003

Third Division, Justice Panganiban
Limitations in filing interpleader

FACTS: The subject property herein is Lot No. 2-G of Subdivision Plan SWO No. 7308 co-
owned by the following siblings: Paulino V. Chanliongco, Jr., Narcisa, Mario and Antonio.
Petitioners herein are the children of Paulino.

However, the subject property was sold by Adoracion Mendoza, daughter of Narcisa, by virtue
of a Special Power of Attorney (in favor of Narcisa) executed by the co-owners, to herein
respondents sometime in 1986. Later, a conflict arose between the heirs of the co-owners as to
the validity of the sale.

Because of this conflict, the respondents filed with the RTC a Complaint for interpleader to
resolve the various ownership claims. Later, the RTC upheld the sale insofar as the share of
Narcisa was concerned. On appeal, the CA modified the RTC disposition, ruling that the sale
was valid even though it was Adoracion who made such sale, as sub-agent of Narcisa.
Subsequently, this became final and was entered in favor of respondents.

Thereafter, petitioners filed with the CA a Motion to Set Aside the Decision contending that they
were not served with the copy of the Complaint or the summons; they were not even impleaded
as parties to the case.

The CA, however, denied the motion, on the ground, among others, that petitioners have no legal
standing. Hence, this petition.

ISSUE: Whether petitioners have legal standing to question the disposition of the lower courts in
the Complaint for Interpleader.

HELD: The Supreme Court held in the negative. It ratiocinated as follows:

“The Complaint filed by respondents with the RTC called for an interpleader to determine the
ownership of the real property in question. Specifically, it forced persons claiming an interest in
the land to settle the dispute among themselves as to which of them owned the property.
Essentially, it sought to resolve the ownership of the land and was not directed against the
personal liability of any particular person. It was therefore a real action, because it affected title
to or possession of real property. As such, the Complaint was brought against the deceased
registered co-owners: Narcisa, Mario, Paulino and Antonio Chanliongco, as represented by their
respective estates.

Clearly, petitioners were not the registered owners of the land, but represented merely an
inchoate interest thereto as heirs of Paulino. They had no standing in court with respect to
actions over a property of the estate, because the latter was represented by an executor or
administrator. Thus, there was no need to implead them as defendants in the case, inasmuch as
the estates of the deceased co-owners had already been made parties.”

WHEREFORE, the Petition is hereby DENIED and the assailed Resolution AFFIRMED.

Wack Wack Golf & Country Club, Inc. v. Won, G.R. No. L-23851, March 26, 1976
En Banc, Justice Castro
Limitations in filing interpleader

FACTS: The subject matter of the case is the Membership Fee Certificate 201 issued by
petitioner Wack Wack Golf & Country Club, Inc.

Petitioner Club filed this Interpleader action in 1963 on the basis of alleged contradicting claims
by respondents Lee Won and Bienvenido Tan.

Bienvenido Tan claims that he is the lawful owner of the certificate pursuant to an assignment
made in his favor by Swan, Culbertson and Fritz, the original owner and holder of said subject
certificate.
On the other hand, however, prior to the filing of said this interpleader action, Lee became a
judgment creditor in civil case 26044 where the CFI awarded to him said certificate.

Petitioner Club prayed that an order be issued requiring Lee and Tan to interplead and litigate
their conflicting claims and that judgment be rendered declaring who is the lawful owner of said
certificate.

Later, the respondents moved for the dismissal of the complaint on the grounds of res judicata,
failure to state a cause of action, and bar by prescription. These were opposed by petitioner.
However, the trial court granted the same on the ground of res judicata and failure to state a
cause of action. Hence, this petition. Petitioner argued that the trial court erred in dismissing the
complaint, instead of compelling the appellees to interplead because there actually are
conflicting claims between the Lee and Bienvenido with respect to the ownership of the
certificate.

ISSUE: The main issue, as clarified by the SC, in this case is: whether the interpleader action
was timely and properly filed.

HELD: No, the action was not filed timely and properly. It ratiocinated as follows:

“The action of interpleader x x x is a remedy whereby a person who has personal property in
his possession, or an obligation to render wholly or partially, without claiming any right to
either, comes to court and asks that the persons who claim the said personal 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 [thereto]. The remedy is afforded
to protect a person not against double liability but against double vexation in respect of one
liability.

There is no question that the subject matter of the present controversy, i.e., the membership fee
certificate 201, is proper for an interpleader suit. What is here disputed is the propriety and
timeliness of the remedy in the light of the facts and circumstances obtaining.

A stakeholder should use reasonable diligence to hale the contending claimants to court. He
need not await actual institution of independent suits against him before filing a bill of
interpleader. He should file an action of interpleader within a reasonable time after a dispute
has arisen without waiting to be sued by either of the contending claimants. Otherwise, he may
be barred by laches or undue delay. But where he acts with reasonable diligence in view of the
environmental circumstances, the remedy is not barred.

Has the Corporation in this case acted with diligence, in view of all the circumstances, such that
it may properly invoke the remedy of interpleader? We do not think so. It was aware of the
conflicting claims of the appellees with respect to the membership fee certificate 201 long before
it filed the present interpleader suit. It had been recognizing Tan as the lawful owner thereof. It
was sued by Lee who also claimed the same membership fee certificate. Yet it did not interplead
Tan. It preferred to proceed with the litigation (civil case 26044) and to defend itself therein. As
a matter of fact, final judgment was rendered against it and said judgment has already been
executed. It is x x x therefore too late for it to invoke the remedy of interpleader.

It has been held that a stakeholder's action of interpleader is too late when filed after judgment
has been rendered against him in favor of one of the contending claimants, especially where he
had notice of the conflicting claims prior to the rendition of the judgment and neglected the
opportunity to implead the adverse claimants in the suit where judgment was entered. This
must be so, because once judgment is obtained against him by one claimant he becomes liable to
the latter.

The Corporation has not shown any justifiable reason why it did not file an application for
interpleader in civil case 26044 to compel the appellees herein to litigate between themselves
their conflicting claims of ownership. It was only after adverse final judgment was rendered
against it that the remedy of interpleader was invoked by it. By then it was too late, because to
be entitled to this remedy the applicant must be able to show that [it] has not been made
independently liable to any of the claimants. And since the Corporation is already liable to Lee
under a final judgment, the present interpleader suit is clearly improper and unavailing.

'It is the general rule that before a person will be deemed to be in a position to ask for an order
of intrepleader, he must be prepared to show, among other prerequisites, that he has not
become independently liable to any of the claimants.

It is also the general rule that a bill of interpleader comes too late when it is filed after judgment
has been rendered in favor of one of the claimants of the fund, this being especially true when the
holder of the funds had notice of the conflicting claims prior to the rendition of the judgment and
had an opportunity to implead the adverse claimants in the suit in which the judgment was
rendered.'

Indeed, if a stakeholder defends a suit filed by one of the adverse claimants and allows said suit
to proceed to final judgment against him, he cannot later on have that part of the litigation
repeated in an interpleader suit. In the case at hand, the Corporation allowed civil 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 situation, it is clear that this interpleader suit
cannot prosper because it was filed much too late.

'If a stakeholder defends a suit by one claimant and allows it to proceed so far as a judgment
against him without filing a bill of interpleader, it then becomes too late for him to do so x x x
It is one of the main offices of a bill of interpleader to restrain a separate proceeding at law by
a claimant so as to avoid the resulting partial judgment; and if the stakeholder acquiesces in
one claimant's trying out his claim and establishing it at law, he cannot then have that part of
the litigation repeated in an interpleader suit.

It is the general rule that a bill of interpleader comes too late when application therefore is
delayed until after judgment has been rendered in favor of one of the claimants of the fund , and
that this is especially true where the holder of the fund had notice of the conflicting claims prior
to the rendition of such judgment and an opportunity to implead the adverse claimants in the suit
in which such judgment was rendered.'

To now permit the Corporation to bring Lee to court after the latter's successful establishment of
his rights in civil case 26044 to the membership fee certificate 201, is to increase instead of to
diminish the number of suits, which is one of the purposes of an action of interpleader, with the
possibility that the latter would lose the benefits of the favorable judgment. This cannot be done
because having elected to take its chances of success in said civil case 26044, with full
knowledge of all the fact, the Corporation must submit to the consequences of defeat.

Besides, a successful litigant cannot later be impleaded by his defeated adversary in an

interpleader suit and compelled to prove his claim anew against other adverse claimants, as that
would in effect be a collateral attack upon the judgment.

In fine, the instant interpleader suit cannot prosper because the Corporation had already been
made independently liable in civil case 26044 and, therefore, its present application for
interpleader would in effect be a collateral attack upon the final judgment in the said civil case;
the appellee Lee had already established his rights to membership fee certificate 201 in the
aforesaid civil case and, therefore, this interpleader suit would compel him to establish his rights
anew, and thereby increase instead of diminish litigations, which is one of the purposes of an
interpleader suit, with the possibility that the benefits of the final judgment in the said civil case
might eventually be taken away from him; and because the 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.”

ACCORDINGLY, the order of May 28, 1964, dismissing the complaint, is affirmed.