Facts:

The case involves Arturo Balbastro, Jose Perez, Edgardo de la Cruz, Leonardo Villanueva, and Consorcia Halili as the petitioners, against the Court of Appeals, Hon. Walfrido de los Angeles in his capacity as Judge of the Court of First Instance of Rizal, Quezon City Branch IV, and Francisco E. Fernandez as the respondents. The dispute arose from an interpleader action initiated on July 17, 1969, by Chin Keng Long, Lim Bun Kong, and Rajindar Singh, who were lessees of a 10-door apartment located at E. Rodriguez St., Quezon City. They sought clarity on whether to remit the rental payments to private respondent Fernandez or defendant Angela M. Butte. The plaintiffs were uncertain of the rightful owner entitling them to collect the rents. Fernandez, defending his role, claimed to have obtained an ad interim authority to collect the rents, a claim he argued was upheld by a prior appellate ruling. Conversely, Angela M. Butte asserted she was the rightful landlord based on ownership of

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Facts:

Background of the Dispute

• On July 17, 1969, three lessees—Chin Keng Long, Lim Bun Kong, and Rajindar Singh—of a 10-door apartment located at E. Rodriguez St., Quezon City, filed a complaint for interpleader and consignation in Civil Case No. Q-13297 before the Court of First Instance of Rizal, Quezon City Branch IV.
• The complaint was directed against private respondent Francisco E. Fernandez and Angela M. Butte, each asserting ownership over the apartment and the right to collect the rents.
• The plaintiffs alleged that, due to conflicting claims, they could not determine with certainty to whom rental payments should be made.

Emergence of the Third-Party Complaint

• In his answer, defendant Francisco E. Fernandez asserted that, pending the final determination of ownership, he had been granted ad interim authority to collect and deposit the rentals due on the property.
• Conversely, defendant Angela M. Butte claimed ownership of the apartment and the right to collect rents accordingly.
• On October 29, 1969, Fernandez proceeded to file a Third-Party Complaint against the petitioners (the lessees occupying the remaining doors) on the ground that they had refused to acknowledge his authority to collect rents from the doors they leased.

Procedural Posturing and Motions

• In response to the filing of the Third-Party Complaint, the petitioners filed a Motion to Strike Out and/or Dismiss the complaint, arguing that:
• The filing violated the express provisions of Section 12, Rule 6 of the Revised Rules of Court.
• The complaint failed to allege a valid cause of action.
• Private respondent Fernandez filed his opposition to the petitioners’ motion on November 14, 1969.
• The trial court (Court of First Instance of Rizal, QC Branch IV) denied the petitioners’ motion on November 17, 1969, and again denied their subsequent Motion for Reconsideration on May 18, 1970.

Appeal and Certification Process

• The petitioners appealed to the Court of Appeals seeking:
• The annulment and setting aside of the trial court’s orders denying their motions.
• The dismissal of the Third-Party Complaint.
• A prohibition restraining the trial court from proceeding with the Third-Party Complaint and/or civil case.
• On January 20, 1971, the Court of Appeals rendered its decision dismissing the petition and dissolving a previously issued writ of preliminary injunction.
• A motion for reconsideration by the petitioners was ultimately denied on February 16, 1971, leading to the present petition for certiorari.

Issue:

• Whether the respondent trial court committed a grave abuse of discretion by allowing Francisco E. Fernandez to file a Third-Party Complaint against the petitioners, thereby including them as parties in Civil Case No. Q-13297.
• Whether the filing of the Third-Party Complaint conforms to the provisions and underlying policy of Section 12, Rule 6 of the Revised Rules of Court, particularly regarding the requirement of establishing a secondary or derivative liability.
• Whether the inclusion of the petitioners in the case, by way of a Third-Party Complaint, results in a more efficient, expeditious, and cost-effective resolution of all related disputes, thereby justifying the trial court’s ruling despite questions regarding its technical correctness.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)