Case Digest (G.R. No. 85868)
Facts:
The case involves Allied Banking Corporation (petitioner) and Joselito Z. Yujuico (respondent). On April 1, 1976, Yujuico secured a loan of Five Hundred Thousand Pesos (₱500,000.00) from the General Bank and Trust Company (GENBANK), which he documented through a promissory note. At the time of the loan, Yujuico was a senior officer of GENBANK and part of the family that owned a controlling interest in the bank. However, on March 25, 1977, the Monetary Board of the Central Bank issued Resolution No. 675, prohibiting GENBANK from conducting business in the Philippines, followed by Resolution No. 677 on March 29, 1977, which mandated the bank's liquidation. Subsequently, on May 9, 1977, Allied Banking Corporation acquired GENBANK's assets and liabilities, including Yujuico's promissory note.
After Yujuico defaulted on the loan, Allied filed a collection suit against him on February 7, 1979, which was registered as Civil Case No. 121474 in the Court of First Instanc...
Case Digest (G.R. No. 85868)
Facts:
Loan Agreement and Promissory Note:
On April 1, 1976, private respondent Joselito Z. Yujuico obtained a loan of P500,000 from General Bank and Trust Company (GENBANK), payable on or before April 1, 1977. A promissory note was issued as evidence of the loan. At the time, Yujuico was a ranking officer of GENBANK and a member of the family owning the controlling interest in the bank.Liquidation of GENBANK:
On March 25, 1977, the Monetary Board of the Central Bank issued Resolution No. 675, prohibiting GENBANK from doing business. This was followed by Resolution No. 677 on March 29, 1977, ordering the liquidation of GENBANK.Acquisition of GENBANK’s Assets by Allied Banking Corporation (ALLIED):
On May 9, 1977, ALLIED entered into a Memorandum of Agreement with Arnulfo Aurellano, the Liquidator of GENBANK, acquiring all of GENBANK’s assets and assuming its liabilities, including the promissory note issued by Yujuico.Collection Suit Filed by ALLIED:
After Yujuico failed to pay the loan, ALLIED filed a collection suit on February 7, 1979, docketed as Civil Case No. 121474 before the Court of First Instance of Manila (now Regional Trial Court).Third-Party Complaint:
In 1987, Yujuico filed a Motion to Admit Amended/Supplemental Answer and Third-Party Complaint, seeking to implead the Central Bank and Arnulfo Aurellano as third-party defendants. He alleged that the Central Bank’s tortious interference with GENBANK’s affairs prevented him from fulfilling his obligation, and thus, he should not be held liable.Trial Court’s Denial of Third-Party Complaint:
The Regional Trial Court denied the admission of the third-party complaint but allowed the amended/supplemental answer. This decision was reiterated by Judge Domingo D. Panis on February 29, 1988, and later affirmed on April 18, 1988.Court of Appeals’ Decision:
Yujuico filed a petition for certiorari with the Court of Appeals, which ruled in his favor on September 5, 1988. The appellate court found grave abuse of discretion in the trial court’s denial of the third-party complaint and ordered its admission.Petition to the Supreme Court:
ALLIED filed a petition for review on certiorari, challenging the Court of Appeals’ decision. The Supreme Court reversed the appellate court’s ruling, reinstating the trial court’s orders denying the third-party complaint.
Issue:
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Ruling:
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Ratio:
Third-Party Complaint Requirements:
A third-party complaint is a procedural device that allows a defendant to bring in a third party who may be liable for all or part of the plaintiff’s claim. The claim must arise out of the same transaction or be connected to the plaintiff’s claim. While Yujuico’s third-party complaint was connected to the main claim, it introduced issues that were not directly related to the promissory note, causing unnecessary delay.Prescription of Cause of Action:
The cause of action for quasi-delict (tortious interference) prescribes in four years from the date the cause of action accrues. In this case, the cause of action accrued on March 25, 1977, when the Monetary Board ordered GENBANK to cease operations. The third-party complaint, filed on June 17, 1987, was beyond the prescriptive period and thus barred.Doctrine of Relations Back:
Yujuico argued that the cause of action accrued only on December 12, 1986, when the Court of Appeals’ decision annulling GENBANK’s liquidation became final. However, the Supreme Court rejected this argument, holding that the prescriptive period begins from the date of the act or omission giving rise to the cause of action, not from the date of a subsequent judicial determination.Judicial Efficiency:
The Court emphasized that while third-party complaints can help clarify issues arising from a single transaction, they should not introduce unrelated controversies that delay the resolution of the main case.