Case Digest (G.R. No. L-24693)
Facts:
This case involves a dispute among United Coconut Planters Bank (petitioner), Makati Bel-Air Condominium Developers, Inc. (private respondent), and Altiura Investors, Inc. The controversy arose in July 1979 when petitioner Bank issued a manager’s check amounting to P494,000.00 payable to Makati Bel-Air, which was bought by Altiura as part payment for an office condominium unit in the Cacho-Gonzales Building. Altiura delivered the check to Makati Bel-Air, but shortly thereafter instructed the Bank to hold payment due to a discrepancy in the size of the purchased unit—the actual area was smaller than the contract specification. The Bank communicated with Makati Bel-Air, requesting reasons against the stop payment order. Makati Bel-Air responded explaining its position and suggested a reduction in the purchase price. Altiura requested that the Bank hold payment while negotiations continued. However, Makati Bel-Air refused to hold the presentation of the check. Consequently, petiti
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Case Digest (G.R. No. L-24693)
Facts:
- Parties and Nature of the Case
- Petitioner: United Coconut Planters Bank (the Bank).
- Respondents: Makati Bel-Air Condominium Developers, Inc. (Makati Bel-Air), and Altiura Investors, Inc. (Altiura).
- The Bank filed a complaint-in-interpleader concerning a manager's check worth P494,000.00 issued by the Bank payable to Makati Bel-Air, which had been purchased by Altiura as partial payment for an office condominium unit.
- Chronology and Key Events
- July 16, 1979: Altiura delivered the manager’s check to Makati Bel-Air.
- July 17, 1979: Altiura instructed the Bank to stop payment due to a discrepancy in the condominium unit’s area (actual: 124.58 sqm vs. contractual: 165 sqm).
- July 17-19, 1979: The Bank requested Makati Bel-Air to explain why it should not issue a stop payment; Makati Bel-Air proposed a possible price reduction, but did not agree to hold presentation of check.
- July 19, 1979: The Bank requested both parties to settle within 15 days, but Makati Bel-Air disagreed.
- July 20, 1979: Due to the disagreement, the Bank filed an interpleader to have the court determine rightful claim to the funds and to authorize deposit of the check proceeds into a special account.
- August 18, 1979: Makati Bel-Air filed an answer with a counter-claim against the Bank and a cross-claim against Altiura. Altiura answered and moved to dismiss the cross-claim.
- July 23, 1979: Altiura filed a separate complaint for rescission of the contract and damages against Makati Bel-Air, later consolidated with the interpleader case.
- August 29, 1979: The Bank moved to withdraw the interpleader complaint and to dismiss Makati Bel-Air’s counter-claim, stating no dispute remained as Makati Bel-Air rescinded the sale and relinquished claim to funds.
- September 28, 1979: Makati Bel-Air returned the original manager's check to the Bank.
- February 18, 1980: Trial court ordered release of funds to Altiura.
- April 28, 1983: Trial court declared Bank’s motion to withdraw interpleader moot/academic due to earlier release order and granted consolidation of related cases.
- July 12, 1983: Trial court clarified the dismissal of Makati Bel-Air’s counter-claim on the basis the funds were released without objection; denied Altiura’s motion to dismiss the cross-claim.
- Makati Bel-Air sought reconsideration, which was denied. It then petitioned the appellate court.
- June 27, 1985: The Intermediate Appellate Court nullified the trial court’s dismissal of Makati Bel-Air’s counter-claim, ruling that withdrawal/dismissal of the Bank’s interpleader complaint did not ipso facto dismiss the counter-claim since it was based on a different cause of action.
Issues:
- Whether Makati Bel-Air’s counter-claim was compulsory and thus was dismissed when the Bank withdrew the complaint-in-interpleader.
- Whether the dismissal of the complaint-in-interpleader also operates as dismissal of the counter-claim filed by Makati Bel-Air.
- Whether the Bank acted properly in filing the complaint-in-interpleader and following orders releasing the funds to Altiura.
- Whether Makati Bel-Air was a holder in due course of the manager’s check.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)