Case Digest (G.R. No. L-23851) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Wack Wack Golf & Country Club, Inc. v. Lee E. Won alias Ramon Lee and Bienvenido A. Tan (En Banc, G.R. No. L-23851, decided March 26, 1976 under the 1973 Philippine Constitution), the non-stock civic and athletic corporation Wack Wack Golf & Country Club, Inc. (hereinafter the Corporation), with principal office in Mandaluyong, Rizal, filed Civil Case No. 7656 before the Court of First Instance of Rizal by way of interpleader. In its amended complaint dated October 23, 1963, the Corporation alleged that two conflicting claimants asserted ownership over its Membership Fee Certificate No. 201 originally issued to “Swan, Culbertson and Fritz.” Defendant Lee E. Won, by virtue of a decision in CFI Manila Civil Case No. 26044 and a certificate issued October 17, 1963 (Serial No. 1478), claimed title to Certificate 201. Defendant Bienvenido A. Tan, having secured Serial No. 1199 on July 24, 1950 via assignment, also claimed the same certificate. The Corporation disclaimed any propri Case Digest (G.R. No. L-23851) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Plaintiff-Appellant: Wack Wack Golf & Country Club, Inc. (the Corporation), a non-stock, civic and athletic corporation organized under Philippine laws with principal office in Mandaluyong, Rizal.
- Defendants-Appellees:
- Lee E. Won alias Ramon Lee (hereinafter “Lee”).
- Bienvenido A. Tan (hereinafter “Tan”).
- Complaint and Procedural History
- First Cause of Action (Amended Complaint, October 23, 1963)
- Lee claims ownership of Membership Fee Certificate No. 201 by virtue of:
- Decision in CFI Manila Civil Case No. 26044 (“Manila Case”).
- Membership Fee Certificate No. 201-Serial No. 1478 issued October 17, 1963 by the CFI Manila’s deputy clerk.
- Tan claims ownership of the same Certificate No. 201 by virtue of Membership Fee Certificate No. 201-Serial No. 1199 issued July 24, 1950 pursuant to an assignment by the original holder “Swan, Culbertson and Fritz.”
- The Corporation alleges no interest in Certificate No. 201, cannot determine the lawful owner, and is prevented by its articles and by-laws from issuing duplicate certificates.
- Second Cause of Action
- The 1963 certificate issued to Lee is null and void for failure to surrender and cancel the outstanding certificate and lack of required corporate signatures.
- The Manila Case decision is not binding on Tan.
- Tan joined as party for complete relief and due to his refusal to bring a separate action.
- Prayer for Relief
- Order Lee and Tan to interplead and litigate their conflicting claims.
- Judgment declaring the lawful owner of Certificate No. 201 and ordering cancellation of the certificate issued to Lee.
- Motions to Dismiss (filed by Lee and Tan)
- Grounds: res judicata, failure to state a cause of action; Tan alone pleaded prescription.
- Opposed by the Corporation.
- Trial Court Disposition
- Found the complaint barred by res judicata and failure to state a cause of action.
- Dismissed the complaint with costs against the Corporation.
- Appeal
- Appellant’s contentions:
- Complaint valid for interpleader; not a collateral attack on the Manila Case.
- No identity of parties, subject-matter, or cause of action—Manila Case does not bar present suit.
- Court should compel interpleader, not dismiss.
Issues:
- Whether the Corporation’s amended complaint states a valid cause of action for interpleader under Section 120 of the Code of Civil Procedure (now Rule 63, Sec. 1, Rules of Court).
- Whether the decision in CFI Manila Civil Case No. 26044 operates as res judicata, barring the interpleader action.
- Whether the Corporation’s failure to implead Tan and its defense in the Manila Case until final judgment renders the interpleader remedy untimely and barred by laches or independent liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)