Case Digest (G.R. No. 170498)
Facts:
Metropolitan Bank & Trust Company v. Absolute Management Corporation, G.R. No. 170498, January 09, 2013, the Supreme Court Second Division, Brion, J., writing for the Court.
The original plaintiff was Sherwood Holdings Corporation, Inc. (SHCI), which on October 5, 2000 filed a complaint for sum of money against Absolute Management Corporation (AMC) in the Regional Trial Court (RTC) of Quezon City, Branch 80 (Civil Case No. Q-00-42105). SHCI alleged it made advance payments to AMC totaling P12,277,500.00 by means of several Metrobank checks that were given to Jose L. Chua, AMC’s general manager. Chua died in 1999 and a separate special proceeding for settlement of his estate (Special Proceedings No. 99-0023) was pending before the RTC of Pasay City at the time.
AMC answered SHCI’s complaint, counterclaimed, and filed a third-party claim seeking to hold Metropolitan Bank & Trust Company (Metrobank) liable should AMC be adjudged liable to SHCI. Metrobank moved for a bill of particulars and later to strike out the third-party complaint after AMC failed to comply; the RTC deferred and instead allowed interrogatories and repeatedly directed AMC to file a bill of particulars, which AMC did not submit. Metrobank also filed a motion to dismiss AMC for alleged forum shopping, which the RTC denied. Metrobank then sought leave to file a fourth‑party complaint against Chua’s estate (seeking reimbursement should Metrobank be found liable), but the RTC denied the motion in an order dated May 7, 2004 and denied reconsideration on July 7, 2004.
Metrobank filed a petition for certiorari under Rule 65 before the Court of Appeals (CA), which affirmed the RTC in a decision dated August 25, 2005 and a resolution dated November 17, 2005, holding that Metrobank’s claim was a money claim arising from implied/quasi‑contract and should have been filed as a claim in the judicial settlement of Chua’s estate under Section 5, Rule 86 of the Rules of Court. Metrobank then...(Subscriber-Only)
Issues:
- Does Metrobank’s petition for review on certiorari comply with Section 4, Rule 45 of the Rules of Court?
- May Metrobank be allowed to file a fourth‑party complaint against the Estate of Jose L. Chua in the RTC ordinary civil action, or must that claim be filed in the special proceeding for settlement of Chua’s estate ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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