Title
Supreme Court
Rizal Commercial Banking Corp. vs. Metro Container Corp.
Case
G.R. No. 127913
Decision Date
Sep 13, 2001
A dispute over rental payments arose after a foreclosure sale, resolved by an unlawful detainer ruling, rendering the interpleader action moot.

Case Digest (G.R. No. 127913)
Expanded Legal Reasoning Model

Facts:

  • Loan and foreclosure
    • On 26 September 1990, Ley Construction Corporation (LEYCON) contracted a ₱30,000,000 loan from Rizal Commercial Banking Corporation (RCBC), secured by a real estate mortgage on property covered by TCT No. V-17223 in Barrio Ugong, Valenzuela.
    • LEYCON defaulted, prompting RCBC to initiate extrajudicial foreclosure, which was conducted on 28 December 1992, with RCBC as highest bidder.
    • LEYCON filed Civil Case No. 4037-V-93 for Nullification of Extrajudicial Foreclosure Sale and Damages against RCBC before RTC Valenzuela, Branch 172.
    • Upon expiration of the 12-month redemption period, title consolidated in favor of RCBC (TCT No. V-332432), and RCBC thereafter demanded rental payments from Metro Container Corporation (METROCAN), the property’s lessee.
  • Unlawful detainer and interpleader proceedings
    • On 26 May 1994, LEYCON sued METROCAN for Unlawful Detainer (Civil Case No. 6202) before MeTC Valenzuela, Branch 82, seeking recovery of rentals.
    • On 27 May 1994, METROCAN filed an interpleader (Civil Case No. 4398-V-94) against LEYCON and RCBC in RTC Valenzuela, Branch 75, to determine rightful recipient of rental payments.
    • On 4 July 1995, following an amicable settlement between METROCAN and LEYCON (rental repayments to LEYCON), the RTC dismissed the interpleader as to those two parties.
    • On 31 October 1995, the MeTC rendered final judgment in Civil Case No. 6202 ordering METROCAN to pay LEYCON all rentals due.
    • On 1 February 1996, METROCAN and LEYCON moved to dismiss the interpleader as moot and academic; the RTC denied these motions on 12 March and 24 June 1996.
    • METROCAN and LEYCON petitioned the Court of Appeals for certiorari; on 18 October 1996, the CA set aside the RTC orders and dismissed Civil Case No. 4398-V-94. RCBC’s motion for reconsideration was denied on 8 January 1997.
    • RCBC then filed a petition for review on certiorari before the Supreme Court.

Issues:

  • Whether the MeTC decision in the unlawful detainer case rendered moot and academic the interpleader action.
  • Whether a party to an interpleader action may unilaterally move for dismissal after answers have been filed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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