DIGEST/LINALYN BATION/INTERPLEADER: RIZAL COMMERCIAL BANKING CORPORATION vs METRO CONTAINER CORPORATION

 

[G.R. No. 127913. September 13, 2001.]

RIZAL COMMERCIAL BANKING CORPORATION, Petitioner, v. METRO CONTAINER CORPORATION, Respondent.

FACTS:

    Ley Construction Corporation (LEYCON) contracted a loan from Rizal Commercial Banking Corporation (RCBC) secured by a real estate mortgage over a property. LEYCON failed to settle its obligation hence, RCBC instituted an extrajudicial foreclosure proceedings against it, with RCBC being the highest bidder.

    Nullification of Extrajudicial Foreclosure Sale and Damages against RCBC was filed by LEYCON. Due to failure of LEYCON to redeem it within the 12-month redemption period, RCBC consolidated its ownership over the property. RCBC then demanded rental payments from Metro Container Corporation (METROCAN) which was leasing the property from LEYCON.

    On the other hand, LEYCON filed an action for Unlawful Detainer against METROCAN. Consequently, 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.

    Judgment was rendered in the unlawful detainer case, ordering METROCAN to pay LEYCON whatever rentals due on the subject premises. Said judgment became final and executory.

    METROCAN and LEYCON separately filed a motion for the dismissal of the complaint of interpleader, for having been moot and academic.

    However, both motions were dismissed for lack of merit. The motions for reconsideration filed by METROCAN and LEYCON were also denied prompting METROCAN to seek relief from the Court of Appeals via a petition for certiorari and prohibition with prayer for the issuance of a temporary restraining order and a writ of preliminary injunction. LEYCON, as private respondent, also sought for the nullification of the RTC orders.

 

ISSUE:

    Whether or not METROCAN, the one who initiated the interpleader can unilaterally dismiss the interpleader case

 

RULING:

    Yes. Section 1, Rule 63 of the Revised Rules of Court 2 provides “whenever conflicting claims upon the same subject matter are or may be made against a person, who claims no interest whatever in the subject matter, or an interest which in whole or in part is not disputed by the claimants, he may bring an action against the conflicting claimants to compel them to interplead and litigate their several claims among themselves.”

    It is undisputed that METROCAN filed the interpleader action 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.

    Hence, the reason for the interpleader action ceased when the court directed METROCAN to pay LEYCON. While RCBC, could not be bound by the judgment therein, METROCAN is bound by the MeTC decision. When the decision 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.

    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.