RIZAL COMMERCIAL BANKING

CORPORATION vs. METRO CONTAINER

CORPORATION

On 26 September 1990, Ley Construction Corporation

(LEYCON) contracted a loan from Rizal Commercial
Banking Corporation (RCBC) in the amount of Thirty Million
Pesos (P30,000,000.00). The loan was secured by a real
estate mortgage over a property, located in Barrio Ugong,
Valenzuela, Metro Manila (now Valenzuela City) and
covered by TCT No. V-17223. LEYCON failed to settle its
obligations prompting RCBC to institute an extrajudicial
foreclosure proceedings against it. After LEYCONs legal
attempts to forestall the action of RBCB failed, the
foreclosure took place on 28 December 1992 with RCBC as
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 LEYCONs failure to redeem it within the 12-
month redemption period and TCT No. V-332432 was issued
if favor of the bank. By virtue thereof, RCBC demanded
rental payments from Metro Container Corporation
(METROCAN) which was leasing the property from
LEYCON.
On 26 May 1994, LEYCON filed an action for Unlawful
Detainer, docketed as Civil Case No. 6202, against
METROCAN before the Metropolitan Trial Court (MeTC) of
Valenzuela, Branch 82.
Issue:
Whether or not an action for interpleader is moot and
academic?

Held:
We sustain the Court of Appeals.

In the case before us, it is undisputed that METROCAN

filed the interpleader action (Civil Case No. 4398-V-94)
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 MeTC rendered judgment in Civil Case No. 6202
whereby the court directed METROCAN to pay LEYCON
whatever rentals due on the subject premises x x x. While
RCBC, not being a party to Civil Case No. 6202, could not
be bound by the judgment therein, METROCAN is bound by
the MeTC decision. When the decision in Civil Case No.
6202 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 Civil Case No.
4398-V-94. 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.
G.R. No. L-41818 February 18, 1976
ZOILA CO LIM, vs.CONTINENTAL DEVELOPTMENT
CORPORATION,

Facts;

That in the books of the plaintiff, there appears the name of the
defendant Benito Gervasio Tan as one of its stockholders initially
sometime in 1975 with fifty (50) common shares covered by of stock
Nos. 12 and 13, and subsequently credited with (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 of the par value of Two Hundred Fifty Pesos
(P250.00) each.
That said defendant Benito Gervasio Tan, personally or through his
lawyer, has since December, 1972, been demanding from by letters
and telegrams, the release to him of the certificates stock aforesaid
but which the plaintiff has not done so far and is prevented from doing
so because of the vehement and adverse claim thereto by the other
defendant, Zoila Co Lim.
That the defendant Zoila Co Lim, by letters sent to the plaintiff
through her counsel, has laid claim and persists in claiming the very
same shares of stock being demanded by the other defendant
alleging that said stocks really belonged to her mother So now
already deceased, and strongly denying her proclaim to the same.

That plaintiff is not sufficiently informed of the right of the respective

claimants and therefore not in a position to determine justly and
correctly their conflicting claims.

Issue: Whether or not an action for interpleader is proper?

Held:

Since there is an active conflict of interests between the two

defendants, now herein respondent Benito Gervasio Tan and
petitioner Zoila Co Lim, over the disputed shares of stock, the trial
court gravely abused its discretion in dismissing the complaint for
interpleader, which practically decided ownership of the shares of
stock in favor of defendant Benito Gervasio Tan. The two defendants,
now respondents in G.R. No. L-41831, should be given full
opportunity to litigate their respective claims.

Rule 63, Section 1 of the New Rules of Court tells us when a cause of
action exists to support a complaint in interpleader:
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 complainants to compel them to interplead and
litigate their several claims among themselves (Italics supplied).
This provision only 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 (Beltran vs. People's Homesite and
Housing Corporation, No. L-25138,29 SCRA 145).