“The action for interpleader protects the plaintiff from cases that may be instituted against him by either or both of the disputing parties”
The action for interpleader is a “remedy whereby a person who has… property in his possession, or an obligation to render… without claiming any right…, comes to court and asks that the persons who claim the… property or who consider themselves entitled to demand compliance… be required to litigate among themselves” (Alvarez v. The Commonwealth of the Philippines, G.R. L-45315, February 25, 1938).
The purpose of the action is to determine who is entitled to the property and who can demand the performance of an obligation.
“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” (G.R. L-45315, February 25, 1938).
In simpler words, the action for interpleader protects the plaintiff from cases that may be instituted against him by either or both of the disputing parties.
By filing an action for interpleader, the plaintiff seeks for the court to determine the rights of the disputing parties, and not to enforce a right that was breached or violated against them since, there is none.
In one Supreme Court case, Lui Enterprises leased a parcel of land in Davao City to Zuellig Pharma Corporation (Zuellig).
During the lease, Zuellig was informed by the Philippine Bank of Communications (PBCom) that it is the new owner of the property and subsequent rental payments should be made to the bank directly (Lui Enterprises, Inc. v. Zuellig Pharma, et al., G.R. 193494, March 12, 2014).
Zuellig informed Lui Enterprises of PBCom’s claim.
However, Lui Enterprises insisted on its right to collect the rentals from Zuellig.
Due to the conflicting claims of Lui Enterprises and PBCom, Zuellig filed a complaint for interpleader with the Regional Trial Court of Makati and consigned the rental payments in court.
Earlier, Lui Enterprises filed an action against PBCom for the nullification of the deed of dation in payment with RTC Davao which it later claimed bars the filing of the interpleader case.
The subject of the nullification case were the properties used by Lui Enterprises to pay its obligations to PBCom.
The Supreme Court said the case to nullify the dation in payment was filed by Lui Enterprises against PBCom, but that the interpleader case was filed by Zuellig against Lui Enterprises and PBCom (G.R. 193494, March 12, 2014).
Different plaintiffs and reliefs were sought in the two cases, thus, litis pendentia (pendency of similar cases) is absent.
In another case, Don Luis Dison Realty, Inc. (Don Luis Realty), as lessor, executed lease contracts with several tenants on its units in San Luis Building, Ermita, Manila.
The tenants were paying their rentals to Francis Pacheco (Pacheco), then General Manager of Don Luis Realty (Pasricha v. Don Luis Dison Realty, Inc., G.R. 136409, March 14, 2008).
After Pacheco was replaced by Roswinda Bautista, the tenants stopped paying the rentals, claiming their refusal to pay was due to the internal squabble in Don Luis Realty as to the person authorized to receive payments.
Hence, Don Luis Realty instituted an action for ejectment against the tenants.
While the main issue in the case is the propriety of the ejectment action instituted by Don Luis Realty against the tenants, the Supreme Court said the internal squabble did not justify the tenants’ failure to pay their rentals.
They should have consigned their payments and commenced an action for interpleader (G.R. 136409, March 14, 2008).
In yet another case, an interpleader action was filed by Bliss Development Corporation (BDC) against Edgar H. Arreza (Arreza) and Montano M. Diaz (Diaz) in RTC Makati regarding the latter’s conflicting claims over a property.
The judgment which later attained finality was in favor of Arreza (G.R. 133113, August 30, 2001).
As a result, Diaz had to deliver the property together with all of its improvements to Arreza.
Thereafter Diaz filed a complaint against BDC and Arreza in RTC Makati to hold them liable for the reimbursement of his acquisition cost and improvements on the property.
The issue to be resolved was whether Diaz’s claims for reimbursement against BDC and Arreza were barred by prior judgment (res judicata) in the interpleader case.
Diaz avers that an interpleader action is nothing more than the determination of rights over the subject matter of the case while his reimbursement case involves recovery of money and damages.
The Supreme Court explained that “[T]he second paragraph of Section 5 of Rule 62 of the 1997 Rules of Civil Procedure provides that the parties in an interpleader action may file counterclaims, cross-claims, third party complaints and responsive pleadings thereto, ‘as provided by these Rules’” (G.R. 133113, August 30, 2001).
The second paragraph of the same Section 5 “expressly authorize[s] the additional pleadings and claims enumerated therein, in the interest of a complete adjudication of the controversy and its incidents.
Hence, Diaz should have filed his claims against Arreza in the interpleader action” (G.R. 133113, August 30, 2001).
Having asserted in the interpleader action his alleged rights as a buyer in good faith, Diaz should have crystallized his demand into specific claims for reimbursement by Arreza. Diaz’s failure to set up his claim for reimbursement in the interpleader action being in the nature of a compulsory counterclaim is now barred (G.R. 133113, August 30, 2001).
The crux of Diaz’s reimbursement case is in the nature of an unpleaded compulsory counterclaim.
There being a prior final judgment in the interpleader case which acquired jurisdiction over the same parties, the same subject property, and the same cause of action, the subsequent reimbursement complaint should be dismissed on the grounds of res judicata (Arreza v. Diaz, G.R. 133113, August 30, 2001)
