Case Digest (G.R. No. 127913)
Facts:
Rizal Commercial Banking Corporation v. Metro Container Corporation, G.R. No. 127913, September 13, 2001, First Division, Kapunan, J., writing for the Court.On 26 September 1990 Ley Construction Corporation (LEYCON) obtained a P30,000,000 loan from Rizal Commercial Banking Corporation (RCBC), secured by a mortgage over a parcel in Barrio Ugong, Valenzuela (TCT No. V-17223). After LEYCON failed to pay, RCBC instituted extrajudicial foreclosure and became the highest bidder at the foreclosure sale held on 28 December 1992. RCBC consolidated title (TCT No. V-332432) after the 12-month redemption period elapsed.
LEYCON filed Civil Case No. 4037-V-93 (Nullification of Extrajudicial Foreclosure Sale and Damages) in the Regional Trial Court (RTC), Valenzuela, Branch 172, challenging the foreclosure. Meanwhile, Metro Container Corporation (METROCAN), which had been leasing the subject property from LEYCON, was presented with RCBC’s demand for rental payments after RCBC’s consolidation of title.
On 26 May 1994 LEYCON sued METROCAN in the Metropolitan Trial Court (MeTC) of Valenzuela, Branch 82, in Civil Case No. 6202 for unlawful detainer (rentals and possession). On 27 May 1994 METROCAN filed an interpleader action, Civil Case No. 4398-V-94, in the RTC of Valenzuela, Branch 75, joining LEYCON and RCBC to determine which of them was entitled to the monthly rents. On 4 July 1995 METROCAN and LEYCON entered an amicable settlement, leading the RTC to dismiss the interpleader insofar as METROCAN and LEYCON were concerned; METROCAN paid back rentals to LEYCON.
On 31 October 1995 the MeTC rendered judgment in Civil Case No. 6202 ordering METROCAN to pay LEYCON "whatever rentals due on the subject premises"; that decision became final and executory. METROCAN and LEYCON moved to dismiss the interpleader (Civil Case No. 4398-V-94) as moot and academic; the RTC denied the motions on 12 March 1996 and again on reconsideration, prompting METROCAN to petition the Court of Appeals for certiorari and prohibition with prayer for TRO and preliminary injunction. LEYCON joined seeking nullification of the RTC orders.
In CA-G.R. SP No. 41294 the Court of Appeals, in a decision promulgated 18 October 1996, granted METROCAN’s petition, set aside the RTC’s 12 March 1996 and 24 June 1996 orders, and ordered dismissal...(Subscriber-Only)
Issues:
- Did the MeTC’s judgment in Civil Case No. 6202 (unlawful detainer) render the interpleader action (Civil Case No. 4398-V-94) moot and academic so as to justify its dismissal?
- May RCBC, as a nonparty to the MeTC case, prevent METROCAN from moving to dismiss the interpleader after answers were filed, or otherwise compel continuation of the interpleader proceeding to adjudica...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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