Case Digest (G.R. No. 127913) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On 26 September 1990, Ley Construction Corporation (LEYCON) obtained a loan of Thirty Million Pesos (₱30,000,000.00) from Rizal Commercial Banking Corporation (RCBC), secured by a real estate mortgage on a Valenzuela City property (TCT No. V-17223). After LEYCON defaulted, RCBC initiated extrajudicial foreclosure, culminating on 28 December 1992 with RCBC as the highest bidder. LEYCON filed Civil Case No. 4037-V-93 for nullification of the foreclosure, but failed to redeem the property within the 12-month period. Title consolidated in RCBC’s name (TCT No. V-332432), leading RCBC to demand rent from Metro Container Corporation (METROCAN), then leasing the premises from LEYCON. On 26 May 1994, LEYCON sued METROCAN for unlawful detainer (Civil Case No. 6202) in the Metropolitan Trial Court (MeTC) of Valenzuela, while on 27 May 1994 METROCAN filed an interpleader before the Regional Trial Court (RTC) of Valenzuela, Branch 75 (Civil Case No. 4398-V-94), to resolve competing claims by Case Digest (G.R. No. 127913) Expanded Legal Reasoning Model
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)