Case Summary (G.R. No. 170498)
Metrobank’s Defensive and Offensive Maneuvers
Metrobank sought clarification via a bill of particulars, prompting AMC’s noncompliance and Metrobank’s motion to strike AMC’s third-party complaint. Concurrently, Metrobank moved to dismiss AMC’s third-party claim as forum shopping, alleging identical claims pending against Chua’s estate—motions both denied. Metrobank then answered interrogatories, invoked estoppel and gross negligence theories, and moved for leave to file a fourth-party complaint against Chua’s estate to secure reimbursement if held liable to AMC.
RTC’s Denial of the Fourth-Party Complaint
In its May 7, 2004 order (affirmed July 7, 2004 on reconsideration), RTC Quezon City refused Metrobank’s motion, classifying the proposed fourth-party claim as quasi-contractual (“cobro de lo indebido”). It held that money claims arising under implied contracts must be filed as claims in the special proceeding for Chua’s estate under Section 5, Rule 86 of the Rules of Court, over which an ordinary civil court lacks jurisdiction.
Court of Appeals’ Affirmation
The Court of Appeals affirmed, emphasizing lex specialis: Section 5, Rule 86 (special proceedings for estate settlement) governs money claims—due, not yet due, or contingent. Section 11, Rule 6 (ordinary actions) is general and applies only suppletorily. A money claim against a deceased person must therefore be filed in the estate settlement, not as a fourth-party complaint in an ordinary civil action.
Issues Before the Supreme Court
- Did Metrobank’s petition for review comply with Section 4, Rule 45 of the Rules of Court?
- Was Metrobank’s fourth-party complaint against Chua’s estate properly denied?
Compliance with Rule 45, Section 4
Metrobank omitted some adverse‐party pleadings but attached AMC’s opposition to its fourth-party motion and later filed missing documents in its reply. Citing F.A.T. Kee Computer Systems, Inc. v. Online Networks Int’l, Inc., the Court held the omission nonfatal, as procedural rules are to be liberally construed to secure just, speedy, and inexpensive determinations. The record still reflected both parties’ positions, precluding outright dismissal under Section 5, Rule 45.
Quasi-Contracts in Estate Settlement Proceedings
Under Maclan v. Garcia, obligations arising from quasi-contracts are “implied contracts” within the meaning of Rule 86, Section 5. Accordingly, liabilities of a deceased person stemming from quasi-contracts must be filed as claims in the special proceeding for estate settlement.
Nature of Metrobank’s Fourth-Party Claim
Metrobank’s claim seeks reimbursement from Chua’s estate if Metrobank is held liable for depositing AMC checks into Ayala Lumber and Hardware’s account. This resembles solutio indebiti under Civil Code Article 2154, requiring recovery of payments made by mistake to one not entitled to demand them. The necessary elements—undue delivery through mistake and lack of right to receive—are
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Factual Antecedents
- Sherwood Holdings Corporation, Inc. (“SHCI”) filed Civil Case No. Q-00-42105 on October 5, 2000, against Absolute Management Corporation (“AMC”) before the RTC of Quezon City, Branch 80, for sums advanced towards 27,000 pieces of plywood and 16,500 plyboards.
- SHCI alleged payments totaling ₱12,277,500.00 were made by Metrobank check nos. 1407668502, 140768507, 140768530–140768534, all crossed and made payable to AMC; these checks were delivered to Jose L. Chua (AMC’s General Manager) in 1998.
- Jose L. Chua died in 1999; a special proceeding for settlement of his estate (Special Proceedings No. 99-0023) commenced before the RTC of Pasay City, Branch 112, and remained pending.
- SHCI later demanded undelivered goods worth ₱8,331,700.00; AMC’s records contained no matching transactions but disclosed 18 Metrobank checks worth ₱31,807,500.00 issued in 1998, crossed for “payee’s account only,” and payable to AMC.
- In its answer with counterclaims and third-party complaint, AMC disclaimed any receipt of funds from SHCI and joined Metrobank as third-party defendant, alleging Metrobank’s liability on the subject checks.
- Metrobank moved for a bill of particulars to clarify AMC’s ambiguous averments; AMC failed to comply, prompting Metrobank’s motion to strike out the third-party complaint.
- Metrobank also moved to dismiss AMC’s third-party complaint for forum shopping, contending AMC had earlier raised the same claim in Chua’s estate proceedings; this motion was denied.
- After procedural skirmishes—including deferred motions, interrogatories, and a denied motion for reconsideration by AMC—Metrobank filed its own answer admitting deposit of the checks into Ayala Lumber and Hardware (a sole proprietorship owned by Chua), asserting AMC’s implied consent, estoppel, and gross negligence.
- Metrobank then sought leave to file a fourth-party complaint against Chua’s estate to seek reimbursement should it be held liable to AMC.
Regional Trial Court Ruling
- By order dated May 7, 2004 (and reconfirmed July 7, 2004), the RTC of Quezon City, Branch 80, denied Metrobank’s motion for leave to admit its fourth-party complaint.
- The RTC characterized Metrobank’s proposed claim as a “cobro de lo indebido” (quasi-contract for recovery of undue payment), an implied contract obligation that must be filed as a claim in Chua’s estate settlement under Section 5, Rule 86 of the Rules of Court.
- The RTC held that an ordinary civil action court la