G.R. No. 85868 - Allied Banking Corp. vs. Court of Appeals

Joselito Z. Yujuico obtained a loan of P500,000 from General Bank and Trust Company (GENBANK) on April 1, 1976, evidenced by a promissory note.
Yujuico was a ranking officer and part of the family controlling GENBANK.
The Central Bank issued resolutions on March 25 and March 29, 1977, prohibiting GENBANK from conducting business and ordering its liquidation.
Allied Banking Corporation (ALLIED) acquired GENBANK's assets and liabilities, including Yujuico's loan obligation.
ALLIED filed a collection suit against Yujuico on February 7, 1979, after he defaulted on the loan.

In 1987, Yujuico sought to amend his answer and file a third-party complaint against the Central Bank and the liquidator, Arnulfo Aurellano, alleging tortious interference that prevented him from fulfilling his loan obligation.
The Regional Trial Court (RTC) denied the admission of the third-party complaint but allowed the amended answer.
The case was re-raffled to Branch 61 of the RTC, where Judge Domingo D. Panis reiterated the denial of the third-party complaint.
Yujuico filed a petition for certiorari with the Court of Appeals, which found grave abuse of discretion by Judge Panis and ordered the admission of the third-party complaint.

Petitioner ALLIED contended that the Court of Appeals erred in ruling that Judge Panis committed grave abuse of discretion.
Specific errors included:
- The third-party complaint did not state a cause of action.
- The cause of action had already prescribed.
- Admission of the third-party complaint would cause unnecessary delays.
ALLIED also argued that the rule against raising new defenses on appeal does not apply to certiorari actions.

A third-party complaint allows a defendant to bring in a third party to seek contribution, indemnity, or other relief related to the plaintiff's claim.
The third-party complaint is independent of the original complaint and must be connected to the plaintiff's claim.
The Court outlined tests to determine if a third-party claim is "in respect of the plaintiff's claim."

The Court found that Yujuico's claim was based on tortious interference and was connected to the prior decision of the Court of Appeals that annulled GENBANK's liquidation.
The claim for indemnity was deemed to arise from the same transaction as the original complaint, satisfying the necessary legal tests.
The Court acknowledged that while the third-party complaint could introduce complexity, it was relevant to clarify the issues arising from the transaction.

ALLIED argued that the cause of action for tortious interference should have been filed within four years from the date it accrued, which they claimed was March 25, 1977.
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