Rule 62

INTERPLEADER
RULE 62
INTERPLEADER
ANG~CABRERA~CALDINO~CHUPUNGCO~JOSOL~MARAVILLA~SAGUINSIN~SAN JOSE~SUVA~TOLENTINO~TOLENTINO~UY
SPECIAL PROCEEDINGS (SBCA, Monday Class) S.Y 2012-2013
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INTERPLEADER
WACK WACK GOLF & COUNTRY CLUB, INC. vs. LEE E. WON alias RAMON LEE, et al
G.R. No. L-23851. March 26, 1976.
Castro, J.:
Digested by: TOLENTINO, Julie Ann B.
1FACTS:
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 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 "Swan, Culbertson and Fritz. The Wack Wack Golf & Country Club, Inc. (herein after
referred to as the Corporation) filed an action of interpleader in the court a quo to have
defendants litigate among themselves their conflicting claims of ownership, claiming that it claims
no interest whatsoever in the said membership fee certificate 201; that it has no means of
determining who of the two defendants is the lawful owner thereof; that it is without power to issue
two separate certificates for the same membership fee certificate 201, or to issue another
membership fee certificate to the defendant Lee, without violating its articles of incorporation and
by-laws. 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 complaint.
ISSUE: Whether the Corporation properly avails of the remedy of interpleader.
HELD: No. When a stakeholder's action is 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, the interpleader suit is too late and will be
barred by laches or undue delay. The Corporation was aware of the conflicting claims of the parties
with respect to the membership fee certificate 201 long before it filed its 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 of
the civil case and to defend itself therein. Final judgment was rendered against it and said
judgment has already been executed. It is now therefore too late for it to invoke the remedy of
interpleader. Moreso, 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.
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INTERPLEADER
RIZAL COMMERCIAL BANKING CORPORATION vs. METRO CONTAINER CORPORATION
G.R. No. 127913. September 13, 2001.
Kapunan, J.:
Digested by. TOLENTINO, Julie Ann B.
FACTS: 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. 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. Consequently, METROCAN filed a complaint for Interpleader
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. 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.
ISSUE: Whether the Decision in the Ejectment case rendered the complaint for Interpleader moot
and academic.
HELD: Yes. The reason for the interpleader action ceased when the MeTC rendered judgment in
the ejectment case whereby the court directed METROCAN to pay LEYCON "whatever rentals due
on the subject premises because it is limited to the question of physical or material possession of
the premises. The issue of ownership is immaterial therein and the outcome of the case could not
in any way affect conflicting claims of ownership, in this case between RCBC and LEYCON. 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 action against Unlawful Detainer 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 the said case. It is not a party thereto. However, it could not compel
METROCAN to pursue the complaint for Interpleader. 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 the case for Nullification of Extrajudicial Foreclosure Sale and Damages filed by LEYCON
against RCBC.
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INTERPLEADER
LIM vs. CONTINENTAL DEVELOPMENT CORPORATION
G. R. No. L-41818. February 18, 1976.
Makasiar, J.:
FACTS: A complaint for interpleader was filed by Continental Development Corporation (CDC)
against Benito Gervacio Tan and Zoila Co Lim, both alleging to be owners of fifty (50) common
shares covered by certificates of stock Nos. 12 and 13, and subsequently credited with seventy five
(75) shares by way of dividends covered by certificates of stock Nos. 20 and 25, or an outstanding
total stockholding of one hundred twenty five (125) common shares, praying that said defendants
be directed to interplead and litigate their respective claims over the shares of stock in its
possession. Tan alleges ownership of the said stocks because the shares of stock in question are
recorded in the books of petitioner in his name, while Lim claims that said shares of stock had
previously been delivered in trust to the defendant Tan for her (Zoila's) mother and that as the
daughter and heir, she is now the owner of the said shares of stock, which should be delivered to
her 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 complaint for lack of cause of action invoking Section 35 of the
Corporation Law (Act 1459, as amended). CDC and defendant 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.
ISSUE: Whether the trial court correctly dismissed the Interpleader.
HELD: No. The Supreme Court held that since there is an active conflict of interests between the
two defendants over the disputed shares of stock, which the plaintiff-in-interpleader cannot justly
and correctly decide thus rendering it impossible to dispose the shares of stock in question, the
dismissal of the complaint is a grave abuse of the discretion and practically decided the ownership
of the shares of stock in favor of defendant Benito Gervacio Tan without giving full opportunity to
both defendants to litigate their respective claims. It is patent from the pleadings in the lower court
that both defendants Benito Gervasio Tan and Zoila Co Lim assert conflicting rights to the
questioned shares of stock. An interpleader merely demands that there be two or more claimants
to the fund or thing in dispute through separate and different interests. The claims must be adverse
before relief can be granted and the parties sought to be interpleaded must be in a position to
make effective claims. The fund, thing, or duty over which the parties assert adverse claims must
be one and the same and derived from the same source.
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INTERPLEADER
ARREZA vs. DIAZ
G.R. No. 133113. August 30, 2001.
Quisumbing, J.:
FACTS: Bliss Development Corporation is the owner of a housing unit located at Lot 27. Block 30
New Capitol Estates I, Barangay Matandang Balara, Quezon City. In the course of a case involving
a conflict of ownership between petitioner Edgar H. Arreza and respondent Montano M. Diaz, Jr.,
Bliss Development Corporation filed a complaint for interpleader. Respondent asserted his right as
a buyer for value and in good faith of the subject property and asked for relief invoking the
jurisdiction of the court. Respondent, however, did not file a claim for reimbursement. Judgment
was rendered in favor of petitioner, which later attained finality. Respondent Diaz was constrained
to deliver the property with all its improvements to petitioner. Thereafter, respondent filed an action
for reimbursement against petitioner and Bliss Development Corporation representing the cost of
acquisition and improvements on the property. Petitioner moved to dismiss on ground of res
adjudicata. The motion was denied, as well as the motion for reconsideration. On certiorari, the
Court of Appeals dismissed the petition. Motion for its reconsideration was denied, hence, this
recourse.
ISSUE: Whether respondent Diaz's claims for reimbursement against petitioner Arreza are barred
by res adjudicata.
HELD: Yes. In the present case, we find there is an identity of causes of action between the cases
of conflict of ownership and claim for reimbursement. Respondent Diaz's cause of action in the
prior case, now the crux of his present complaint against petitioner, was in the nature of an
unpleaded compulsory counterclaim, which is now barred. There being a former final judgment on
the merits in the prior case, by the Regional Trial Court, which acquired jurisdiction over the same
parties, the same subject property, and the same cause of action, the present complaint of
respondent herein against petitioner Arreza should be dismissed on the ground of res adjudicata.
Pursuant to Section 5 of Rule 62 of the 1997 Rules of Civil Procedure respondent should have filed
his claims against petitioner Arreza in the interpleader action. Having asserted his rights as a buyer
in good faith in his answer, and praying relief therefor, respondent Diaz should have crystallized his
demand into specific claims for reimbursement by petitioner Arreza. This he failed to do. In cases
involving res adjudicata, the parties and the causes of action are identical or substantially the same
in the prior as well as the subsequent action. The judgment in the first action is conclusive as to
every matter offered and received therein and as to any other matter admissible therein and which
might have been offered for that purpose, hence said judgment is an absolute bar to a subsequent
action for the same cause. The bar extends to questions "necessarily involved in an issue, and
necessarily adjudicated, or necessarily implied in the final judgment, although no specific finding
may have been made in reference thereto, and although such matters were directly referred to in
the pleadings and were not actually or formally presented." Said prior judgment is conclusive in a
subsequent suit between the same parties on the same subject matter, and on the same cause of
action, not only as to matters which were decided in the first action, but also as to every other
matter which the parties could have properly set up in the prior suit. Having failed to set up his
claim for reimbursement, said claim of respondent Diaz being in the nature of a compulsory
counterclaim is now barred.
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INTERPLEADER
SY-QUIA vs. THE SHERIFF OF ILOCOS SUR, et al.
G.R. No. L-22807. October 10, 1924.
Ostrand, J.:
FACTS: On February 3, 1915, Miguel Aglipay Cheng-Laco and Feliciano Reyes Cheng-Kiango
executed a chattel mortgage in favor of the petitioner Gregorio R. Sy-Quia on their mercantile
establishment, with all the merchandise therein contained, as security for a debt of P6,000. The
chattel mortgage was duly recorded. From its terms it may be inferred that it was the intention of
the parties that the mortgagors were to be permitted to sell the merchandise replenishing their
stock from time to time and that the new stock brought in should also be subject to the mortgage.
On May 5, 1924, Cheng-Laco executed another chattel mortgage on the same establishment and
all its contents in favor of the Filadelfo de Leon as security for the sum of P4, 900, which was
recorded. On the latter date the petitioner, in writing, requested the sheriff to take possession of the
mortgaged property and to sell it at public auction. The sheriff seized the establishment in question
as well as its contents and fixed the date of the sale. In the meantime Filadelfo de Leon presented
an adverse claim to the property by virtue of his chattel mortgage, alleging that all the goods on
which the chattel mortgage of Sy-Quia was given had seen sold long before the chattel mortgage
in favor of De Leon was executed and that, therefore, the earlier chattel mortgage was of no effect.
The sheriff being in doubt as to the priority of the conflicting claims, suspended the foreclosure
proceedings and brought an action requiring the two claimants to interplead. Petitioner brought a
petition for a writ of mandamus to compel the Sheriff of the Province of Ilocos Sur to proceed with a
chattel mortgage foreclosure sale.
ISSUE: Whether the petition for Mandamus should lie against the respondent.
HELD: No. In respect to conflicting claims to property seized by the sheriff in the foreclosure of a
chattel mortgage, the sheriff may bring an action of interpleader under section 120 of the Code of
Civil Procedure in order to determine the respective rights of the claimants. Though in such cases it
may ordinarily be better practice for the sheriff to sell the property and hold the proceeds of the
same subject to the outcome of the action of interpleader, his action in suspending the sale
pending the determination of the action interpleader seems justified by the facts in the present case
and the court will not interfere by mandamus.
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INTERPLEADER
OCAMPO vs. TIRONA
G.R. No. 147812. April 6, 2005.
Carpio, J.:
FACTS: Ocampo alleged that he is the owner of a parcel of land in Pasay City having bought the
subject land from Rosauro Breton, heir of the subject land's registered owner Alipio Breton Cruz.
Tirona, on the other hand, is a lessee occupying a portion of the subject land, paying her rent to
Maria Lourdes Breton-Mendiola, who is a co-heir with Rosauro Breton for the subject
land. According to Ocampo, upon acquisition of ownership of the subject premises, a formal written
notice and formal written agreement were given to Tirona, which was received by the latter. In
recognition of Ocampo's right of ownership over the subject premises, Tirona paid some monthly
rentals due, however, on July 5, 1995, Ocampo received a letter from stating among others, that, in
view of the fact that the subject premises was declared under area for priority development, Tirona
is invoking her right of first refusal and in connection thereto Tirona will temporarily stop paying her
monthly rentals until and unless the National Housing Authority have processed the pertinent
papers as regards the amount due to Ocampo by reason of the implementation of the above law. In
reply, Ocampo sent a letter letter to Tirona demanding upon her to pay the rentals in arrears and to
vacate the premises.Despite receipt of said letter, Tirona failed and refused and still fails and
refuses to heed Ocampo's demands. Ocampo filed a complaint for Unlawful Detainer and damages
against Tirona. In her answer, Tirona alleged that Ocampo is not the owner of the subject land and
asserted her right of first refusal in case of sale of the land. The trial court ruled in favor of Ocampo.
Tirona, on a petition for review, raised the issue of rightful ownership over the subject land.
ISSUE: Whether the appellate court correctly considered and resolved the issue of ownership
raised in the petition for review for the first time on appeal.
RULING: No. Unlawful detainer being a summary proceeding, it was error for the appellate court to
include the issue of ownership. Had the appellate court limited its ruling to the elements to be
proved in a case of unlawful detainer, Ocampo need not even prove his ownership. When the
appellate court ruled that the case of unlawful detainer had to wait for the results of the partition
proceedings, it effectively put ownership as the main issue in the case. The issue of ownership
opens a virtual Pandora's Box for Tirona and her supposed intervenor, Maria Lourdes BretonMendiola. The good faith of Tirona is put in question in her preference for Maria Lourdes BretonMendiola. As a stakeholder, Tirona should have used reasonable diligence in hailing the
contending claimants to court. Tirona need not have awaited actual institution of a suit by Ocampo
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. Ocampo has the right to eject Tirona from the subject land. All the elements required for
an unlawful detainer case to prosper are present. Ocampo notified Tirona that he purchased the
subject land from Tirona's lessor. Tirona's continued occupation of the subject land amounted to
acquiescence to Ocampo's terms. However, Tirona eventually refused to pay rent to Ocampo, thus
violating the lease.
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INTERPLEADER
PAGKALINAWAN, et al. vs. RODAS, et al.
G.R. No. L-1806. February 25, 1948.
Paras, J.:
FACTS: In an ejectment suit between Manuel Tambunting, plaintiff, and Alfonso Pagkalinawan and
Manuel Pagkalinawan, defendants, appealed from the municipal court to the Court of First Instance
of Manila, the latter court, after trial, rendered a decision dated sentencing the defendants to
vacate the house in question and to pay to the plaintiff the rentals. Acting upon a motion for
reconsideration filed by the defendants, the Court of First Instance of Manila issued an order
granting said motion, setting aside the decision and absolving the defendants from the complaint.
On motion for reconsideration in turn filed by the plaintiff, an order dated August 16, 1947, was
issued in which the same court "dicta de nuevo sentencia en esta causa, ordenando al Escribano
pague al aqui demandante los alquileres depositados por los demandados hasta la fecha, y que en
adelante dichos demandados paguen al demandante directamente los alquileres, en caso
contrario, el Juzgado ordenara su lanzamiento de la finca en cuestion y les condenara al pago de
las costas." This decision appears to have become final, as a result of which, upon petition of the
plaintiff, the Court of First Instance of Manila ordered the issuance of a writ of execution. The
defendants sought to stay the execution on the ground that they had in the meantime filed with the
same court an interpleader suit against the plaintiff and one Angel de Leon Ong, praying that the
latter two be ordered to litigate their conflicting claims to the rentals due from the defendants for the
premises in question, The Court of First Instance of Manila acceded to the motion for stay of
execution, but, at the instance of the plaintiff, it issued an order directing that execution be
proceeded with.
ISSUE: Whether the respondents should desist from carrying out the writ of execution in
connection with the interpleader.
HELD: Yes. The decision of the respondent judge of August 16, 1947, orders the petitioners to pay
the rentals directly to the respondent M. T. and provides for their ejectment in case of default. In
connection with an interpleader suit filed by the petitioners in the Court of First Instance of Manila,
said rentals were deposited with the clerk of court, of which fact the respondent judge was
informed by the petitioners in their constancia dated October 15, 1947. Held, That such deposits
constitute a bona fide compliance with the decision of the respondent judge justifying stay of
execution. The decision of the respondent judge of August 16, 1947, orders the petitioners to pay
the rentals directly to the respondent M. T. and provides for their ejectment in case of default. In
connection with an interpleader suit filed by the petitioners in the Court of First Instance of Manila,
said rentals were deposited with the clerk of court, of which fact the respondent judge was
informed by the petitioners in their constancia dated October 15, 1947. Held, That such deposits
constitute a bona fide compliance with the decision of the respondent judge justifying stay of
execution.
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INTERPLEADER
MESINA vs. INTERMEDIATE APPELLATE COURT, et al.
G.R. No. 70145. November 13, 1986.
Paras, J.:
FACTS: Respondent Jose Go, on December 29, 1983, purchased from Associated Bank Cashier's
Check for P800,000.00. Unfortunately, Jose Go left said check on the top of the desk of the bank
manager when he left the bank. The bank manager entrusted the check for safekeeping to a bank
official, a certain Albert Uy, who had then a visitor in the person of Alexander Lim, Uy had to answer
a phone call on a nearby telephone after which he proceeded to the men's room. When he
returned to his desk, his visitor Lim was already gone. When Jose Go inquired for his cashier's
check from Albert Uy, the check was not in his folder and nowhere to be found. The latter advised
Jose Go to go to the bank to accomplish a "STOP PAYMENT" order, which suggestion Jose Go
immediately followed. He also executed an affidavit of loss. Albert Uy went to the police to report
the loss of the check, pointing to the person of Alexander Lim as the one who could shed light on it.
The records of the police show that Associated Bank received the lost check for clearing. The
check was immediately dishonored with the words "Payment Stopped" stamped on it. Several days
later respondent Associated Bank received a letter from a certain Atty. Lorenzo Navarro demanding
payment on the cashier's check in question, which was being held by his client. The police sent a
letter to the Manager of the Prudential Bank requesting assistance in identifying the person who
tried to encash the check but said bank refused saying that it had to protect its client's interest and
the identity could only be revealed with the client's conformity. Unsure of what to do on the matter,
respondent Associated Bank filed an action for Interpleader naming as respondent, Jose Go and
one John Doe, Atty. Navarro's then unnamed client who was later identified as Marcelo Mesina in a
case filed by him against the bank for payment of the value of the check. Mesina claimed that the
check came to his possession when it was paid to him by Alexander Lim in a certain transaction.
ISSUE: Whether an interpleader is the proper remedy of the bank in the case at bar.
HELD: Yes. Considering the aforementioned facts and circumstances, respondent bank merely
took the necessary precaution not to make a mistake as to whom to pay and therefore interpleader
was its proper remedy. It has been shown that the interpleader suit was filed by respondent bank
because petitioner and Jose Go were both laying their claims on the check, petitioner asking
payment thereon and Jose Go as the purchaser or owner. The allegation of petitioner that
respondent bank had effectively relieved itself of its primary liability under the check by simply filing
a complaint for interpleader is belied by the willingness of respondent bank to issue a certificate of
time deposit in the amount of P800,000 representing the cashier's check in question in the name of
the Clerk of Court of Manila to be awarded to whoever will be found by the court as validly entitled
to it. Said validity will depend on the strength of the parties' respective rights and titles thereto.
Bank filed the interpleader suit not because petitioner sued it but because petitioner is laying claim
to the same check that Go is claiming. On the very day that the bank instituted the case in
interpleader, it was not aware of any suit for damages filed by petitioner against it.
VDA. DE CAMILO, et al vs. ARCAMO, et al.

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INTERPLEADER
G.R. No. L-15653. September 29, 1961.
Paredes, J:
FACTS: Petitioner Petra Carpio Vda. de Camilo, had been by herself and predecessors-in-interest
in peaceful, open and adverse possession of a parcel of public foreshore land, situated in
Malangas, Zamboanga del Sur. A commercial building was erected on the property. Respondent
Ong Peng Kee was a lessee of one of the apartments of said commercial building since June 1,
1957. On August 1, 1957, Arthur Evert Bannister filed an unlawful detainer case against both De
Camilo and Ong Peng Kee. The other petitioners, Severino Estrada, Felisa, Susana, Antonio and
the minors Isabelo, Rene and Ruben, all surnamed Francisco, the said minors represented by their
mother Susana, had also been in possession (in common), peaceful, open and adverse, since
1937, of a parcel of public foreshore land which is adjoining that land occupied by de Camilo. On
this parcel, the Franciscos erected a commercial building. The two commercial buildings were
burned down. Two weeks thereafter, respondents Ong Peng Kee and Adelia Ong, constructed a
building of their own, occupying about 120 square meters. The building, was so built that portions
of the lands previously occupied by petitioners (De Camilo and the Franciscos) were encroached
upon. De Camilo, Severino Estrada and the Franciscos Camilo filed an action for Forcible Entry
against Ong Peng Kee and Adelia Ong. In answer to the complaints, the defendants (Ong Peng
Kee and Adelia Ong), claimed that the land where they constructed their building was leased to
them by the Municipality of Malangas. Pending trial of the two cases, the respondents Ong Peng
Kee and Adelia Ong filed a complaint for Interpleader against De Camilo, Severino Estrada, the
Franciscos, Arthur Evert Bannister, the Mayor and Treasurer of Malangas.
ISSUE: Whether the Justice of the Peace Court has jurisdiction to take cognizance of the
Interpleader case.
HELD: No. The petitioners did not have conflicting claims against the respondents. Their respective
claim was separate and distinct from the other. They claimed possession of two different parcels of
land, of different areas, adjoining each other. It is, therefore, evident that the requirements for a
complaint of Interpleader do not exist. Even in the supposition that the complaint presented a
cause of action for Interpleader, still We hold that the Justice of Peace had no jurisdiction to take
cognizance thereof. The complaint asking the petitioners to interplead, practically took the case out
of the jurisdiction of the JP court, because the action would then necessarily "involve the title to or
possession of real property or any interest therein" over which the CFI has original jurisdiction (par.
[b], sec. 44, Judiciary Act, as amended). Then also, the subject-matter of the interpleader would
come under the original jurisdiction of the CFI, because it would not be capable of pecuniary
estimation (Sec. 44, par. [a], Judiciary Act), there having been no showing that rentals were asked
by the petitioners from respondents.
BELTRAN, et al. vs. PEOPLE'S HOMESITE & HOUSING CORPORATION, et al.

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INTERPLEADER
G.R. No. L-25138. August 28, 1969.
Teehankee, J.:
FACTS: This interpleader suit was filed on August 21, 1962, by plaintiffs in their own behalf and in
behalf of all residents of Project 4 in Quezon City, praying that the two defendant-government
corporations be compelled to litigate and interplead between themselves their alleged conflicting
claims involving said Project 4. Plaintiffs allege that since they first occupied in 1953 their
respective housing units at Project 4, under lease from the People's Homesite & Housing
Corporation (PHHC) and paying monthly rentals therefore, they were assured by competent
authority that after five years of continuous occupancy, they would be entitled to purchase said
units. On February 21, 1961, the PHHC announced to the tenants that the management,
administration and ownership of Project 4 would be transferred by the PHHC to the Government
Service Insurance System (GSIS) in payment of PHHC debts to the GSIS, as well as the selling
price and mode of payment for the housing units among other things. Subsequently, PHHC through
its new Chairman-General Manager, Esmeraldo Eco, refused to recognize all agreements and
undertakings previously entered into with GSIS, while GSIS insisted on its legal rights to enforce
the said agreements and was upheld in its contention by both the Government Corporate Counsel
and the Secretary of Justice. Plaintiffs thus claimed that these conflicting claims between the
defendants-corporations caused them great inconvenience and incalculable moral and material
damage, as they did not know to whom they should pay the monthly amortizations or payments.
Hence, the interpleader
ISSUE: Whether an interpleader is a proper remedy for the plaintiffs.
HELD: No. The record shows clearly that there were no conflicting claims by defendant
corporations as against plaintiffs' tenants, which they may properly be compelled in an interpleader
suit to interplead and litigate among themselves. Both defendant corporations were agreed that
PHHC should continue receiving the tenants' payments, and that such payments would be duly
recognized even if the GSIS should eventually take over Project 4 by virtue of their turn-over
agreement. Where the two defendant-government corporations sought to be interpleaded as
conflicting claimants have no conflicting claims against plaintiffs (tenants), the special civil action of
interpleader will not lie. While the two defendants corporations may have conflicting claims
between themselves with regard to the management, administration and ownership of Project 4,
such conflicting claims are not against the plaintiffs nor do they involve or affect the plaintiffs. The
resolution of the issue of the right of ownership over the houses and lots in Project 4 and the issue
of the status of the commitments, agreements and undertakings made by the previous PHHC
administration, affecting the defendant corporations exclusively may not properly be sought
through the special civil action of interpleader. Should there be a breach of the PHHC undertakings
toward plaintiffs, plaintiffs' recourse would be an ordinary action of specific performance or other
appropriate suit against either the PHHC or GSIS or both, as the circumstances warrant.
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INTERPLEADER

VDA. DE CAMILO, et al vs. ARCAMO, et al.

BELTRAN, et al. vs. PEOPLE'S HOMESITE & HOUSING CORPORATION, et al.

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