Case Digest (G.R. No. 214074)
Facts:
Philippine National Bank v. Median Container Corporation and Eldon Industrial Corporation, G.R. No. 214074, February 05, 2024, the Supreme Court Second Division, Kho, Jr., J., writing for the Court.On November 2, 2010, Median Container Corporation and Eldon Industrial Corporation (collectively, respondents) filed a complaint for reformation of instrument in the Regional Trial Court (RTC), Branch 91, Quezon City, alleging that although they had obtained financing from Philippine National Bank (PNB), PNB induced them to sign trust receipts that did not reflect their real agreement and which were used to coerce payment under threat of criminal prosecution. Respondents sought equitable reformation to have the written instruments reflect the parties’ true agreement.
PNB answered and filed a counterclaim for recovery of PHP 31,059,616.29, alleging respondents’ unpaid obligations arising from the trust receipts and sought to implead Spouses Carlos and Fely Ley (officers of Median) as jointly and severally liable. PNB contended the trust receipts reflected the real agreement and that respondents defaulted in turning over proceeds or the goods themselves, while respondents maintained the underlying agreement was a loan and sought reformation.
In a Resolution dated February 14, 2011, the RTC dismissed without prejudice PNB’s counterclaim and denied the motion to implead Spouses Ley, reasoning that the counterclaim was permissive (not compulsory) and that PNB failed to pay the required docket fees and file a certificate of non–forum shopping, depriving the court of jurisdiction over the permissive counterclaim. PNB’s motion for reconsideration was denied on July 29, 2011.
PNB petitioned the Court of Appeals (CA) via a petition for certiorari. In a Decision dated March 19, 2014, the CA dismissed the petition for lack of merit, holding that PNB’s counterclaim was permissive because it raised issues (amount due and default under trust receipts) different from respondents’ reformation claim (the parties’ real agreement), and reiterating that PNB had not pa...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in affirming the RTC’s dismissal of PNB’s counterclaim for lack of jurisdiction on the ground that it was permissive and PNB failed to pay docket fees and file a certificate of non–forum shopping?
- Did the RTC and CA err in denying PNB’s motion to implead Spouses Carlos and Fely Ley a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)