Title
Traders Royal Bank vs. Intermediate Appellate Court
Case
G.R. No. 66321
Decision Date
Oct 31, 1984
Traders Royal Bank sued REMCO for debt recovery; La Tondena claimed ownership of attached alcohol. Bulacan court upheld La Tondena's separate action, affirming jurisdiction and non-exclusivity of intervention.

Case Digest (G.R. No. 66321)

Facts:

  • Parties Involved
    • Petitioner: Traders Royal Bank.
    • Respondents:
      • The Hon. Intermediate Appellate Court.
      • Hon. Jesus R. De Vega, Presiding Judge of the Regional Trial Court, Third Judicial Region, Branch IX, Malolos, Bulacan.
      • La Tondena, Inc.
      • Victorino P. Evangelista, in his capacity as ex-oficio Provincial Sheriff of Bulacan, and/or any and all his deputies.
  • Procedural History and Chronology of Events
    • March 18, 1983 – Petitioner's Action
      • Traders Royal Bank instituted a suit against Remco Alcohol Distillery, Inc. in the Regional Trial Court, Branch CX, Pasay City (Civil Case No. 9894-P) for the recovery of P2,382,258.71.
      • A writ of preliminary attachment was obtained, resulting in the levy of assets, specifically including about 4,600 barrels of aged or rectified alcohol at Remco’s premises.
    • The Filing of a Third-Party Claim by La Tondena, Inc.
      • On April 1, 1982, La Tondena, Inc. filed a third-party claim with the deputy sheriff, asserting ownership over the attached property.
      • Subsequently, on May 12, 1982, La Tondena, Inc. filed a complaint-in-intervention in the original suit, contending that it had made advances amounting to P3 million to Remco, which remained outstanding, and claiming ownership of the alcohol.
    • Motions and Orders in the Pasay Court
      • La Tondena, Inc. later filed a Motion to Withdraw in Civil Case No. 9894-P (October 8, 1983) to withdraw alcohol and molasses from Remco’s plant.
      • An order was issued on January 27, 1983, granting the motion for withdrawal.
      • The order was reconsidered on February 18, 1983, with the court declaring that any alcohol not withdrawn remained under Remco’s ownership and denying the motion to intervene.
    • Subsequent Developments by La Tondena, Inc.
      • On March 8, 1983, La Tondena, Inc. filed a motion for reconsideration of the February order, seeking both withdrawal of the alcohol and a reversal of the declaration of ownership.
      • The motion was later withdrawn on July 18, 1983.
    • Filing of an Independent Action Relating to the Disputed Property
      • On July 19, 1983, La Tondena, Inc. initiated an independent suit in the Regional Trial Court, Branch IX, Malolos, Bulacan (Civil Case No. 7003-M).
      • This suit asserted its claim of ownership over the alcohol and sought a writ of preliminary mandatory and prohibitory injunction.
    • Actions and Counteractions in the Malolos Case
      • On July 27, 1983, Traders Royal Bank filed a Motion to Dismiss and/or Opposition to the injunctive relief application filed by La Tondena, Inc.
      • La Tondena, Inc. subsequently filed its opposition on August 1, 1983, which was answered by the petitioner on August 3, 1983.
      • Hearings were conducted on August 8, 19, and 23, 1983, during which both parties submitted memoranda.
    • Issuance of Key Orders
      • On September 28, 1983, the respondent judge of the Malolos RTC issued an order declaring La Tondena, Inc. the owner of the disputed alcohol and granting its requested injunctive relief.
      • On October 6, 1983, Sheriff Victorino Evangelista issued a writ of preliminary injunction based on the September order.
      • Further, on October 14, 1983, the Pasay Court issued an order directing the deputy sheriff to enforce the writ of attachment (from the earlier Pasay proceedings) by preventing the withdrawal or removal of the disputed alcohol.
    • Petitioner’s Petition for Certiorari and Prohibition
      • Traders Royal Bank filed a petition before the Intermediate Appellate Court seeking to annul the September 28 order of the Malolos RTC and dissolve the ensuing writ of injunction.
      • The petition argued that the Malolos RTC had acted without jurisdiction by interfering with the pendency and authority of the Pasay Court’s attachment proceedings.
      • The Intermediate Appellate Court dismissed the petition due to lack of factual and legal basis, a decision reaffirmed by denying the petitioner’s subsequent motion for reconsideration on February 2, 1984.
  • Contentions of the Parties
    • Petitioner’s Argument
      • Traders Royal Bank contended that the Malolos RTC lacked jurisdiction to entertain the third-party claim since the property was already subject to a writ of attachment issued by the Pasay Court.
      • It argued that issuing an injunction ordering the sheriff not to withdraw or sell the alcohol interfered with the corresponding authority and jurisdiction of the Pasay Court.
    • Respondent’s (La Tondena, Inc. and Malolos RTC) Standpoints
      • La Tondena, Inc. asserted its claim of ownership as a third-party claimant, in accordance with Section 14, Rule 57 of the Rules of Court.
      • The Malolos RTC maintained that the independent vindicatory action filed by La Tondena, Inc. was proper and that the court's issuance of an interlocutory injunction was within its jurisdiction to preserve the subject matter and protect the parties’ interests.

Issues:

  • Jurisdiction and Authority
    • Whether the Regional Trial Court of Malolos, Bulacan (Civil Case No. 7003-M) had the jurisdiction to entertain and issue a writ of preliminary injunction in favor of a third-party claimant (La Tondena, Inc.) over property already attached in a separate suit before the Pasay Court.
    • Whether the issuance of the injunctive relief by the Malolos RTC amounted to improper interference with the ongoing attachment proceedings in the Pasay Court.
  • Procedural and Substantive Validity of the Third-Party Claim
    • Whether the third-party claim mechanism under Section 14, Rule 57 of the Rules of Court provides a valid and independent remedy for a claimant asserting ownership over attached property.
    • Whether a separate vindicatory action for ownership, as exemplified by La Tondena, Inc.’s separate suit, is appropriate even if an intervention in the attachment proceeding was previously denied.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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