Case Summary (G.R. No. 214074)
Applicable Law
The case is governed by the 1987 Constitution of the Philippines and the pertinent provisions concerning counterclaims as established under the Rules of Court.
Background of the Case
On November 2, 2010, respondents filed a complaint for Reformation of Instrument against PNB, contending that they were misled into signing trust receipts instead of the expected promissory notes related to a PHP 50 million credit line. PNB's position, articulated through its Answer with Counterclaim, asserted that the trust receipts accurately reflected the agreement and accused the respondents of attempting to evade their financial obligations.
Regional Trial Court (RTC) Ruling
The RTC, in a Resolution dated February 14, 2011, dismissed PNB's counterclaim without prejudice and denied its motion to implead the Spouses Ley, who were the officers of Median. The RTC characterized PNB's counterclaim as permissive, indicating that it was independent of the main complaint regarding the reformation of the instrument. The failure of PNB to pay the required docket fees within the prescribed period resulted in jurisdictional challenges, leading to the dismissal of the counterclaim.
Court of Appeals (CA) Ruling
On March 19, 2014, the CA upheld the RTC's decision, asserting that PNB's counterclaim was permissive and did not spring from the same transactional basis as the complaint for reformation. The CA detailed that the evidence necessary to prove the validity of the trust receipts as opposed to a loan agreement was distinct, thereby justifying the separation of the two claims. Additionally, the CA emphasized PNB's recourse to file a separate action for collection against the respondents.
Issues Presented to the Supreme Court
The Supreme Court was tasked with determining whether the CA erred in agreeing with the RTC regarding the nature of PNB's counterclaim and the denial of the motion to implead the Spouses Ley. PNB argued for the intrinsic link between its counterclaim and the complaint, asserting that both arose from the same set of facts regarding the contractual relationship.
Legal Analysis
The Court noted that a counterclaim is classified as either compulsory or permissive. A counterclaim is compulsory if it relates directly to the opposing party's claim and involves the same set of facts, while a permissive counterclaim does not necessarily relate to the main claim and can be resolved in a separate action. The ruling clarified that PNB’s counterclaim sought distinct evidence regarding payment obligations, separate from the issue of reformation, thereby qualifying it as permissive.
PNB's Argument and Court's Findings
PNB reiterated its belief that its counterclaim should be considered compulsory, citing judicial economy and the interconnectedness of the claims. However, the Court emphasized that the different evidentiary requirements for PNB's counterclaim and the reformation complaint demonstrated that the actions were indeed separate. PNB's failure to fulfill procedural requisites
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Parties and Procedural Posture
- Petitioner: Philippine National Bank (PNB).
- Respondents: Median Container Corporation and Eldon Industrial Corporation.
- Case involves Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Review challenges the Court of Appeals Decision (March 19, 2014) and Resolution (August 18, 2014) affirming RTC rulings (February 14 and July 29, 2011) that dismissed PNB's counterclaim and denied its motion to implead Spouses Carlos and Fely Ley.
Factual Background
- Respondents filed a complaint for Reformation of Instrument alleging that the credit line of PHP 50 million availed from PNB was represented falsely by trust receipts instead of promissory notes.
- Respondents claimed trust receipts did not reflect real agreement and were executed under duress with threats of criminal prosecution.
- PNB, in its Answer with Counterclaim, contended the trust receipts represented the true agreement, executed voluntarily, and accused respondents of evading obligations and potential estafa liability under Trust Receipts Law.
- PNB sought to implead Spouses Ley, officers of Median Container Corporation, for joint and several liability covering unpaid obligations amounting to PHP 31,059,616.29.
RTC Rulings
- RTC dismissed PNB’s counterclaim without prejudice for failure to pay the required docket fees and failure to file a certificate of non-forum shopping, given the counterclaim was permissive and independent from the respondents’ complaint.
- RTC denied PNB’s motion to implead Spouses Ley based on the non-acquisition of jurisdiction over the counterclaim.
- RTC denied PNB’s motion for reconsideration reaffirming the dismissal and denial of impleader motion.
Court of Appeals Ruling
- CA dismissed PNB’s Petition for Certiorari for lack of merit, affirming the RTC decision.
- CA held that PNB’s counterclaim for recovery of proceeds or goods unpaid under trust receipts was permissive, not compulsory.
- CA distinguished the necessary evidence and legal issues between the petition for reformation (real nature of agreement) and the counterclaim for collection (payment default).
- Emphasized procedural requirement that permissive counterclaims must be accompanied by payment of prescribed docket fees for the RTC to gain jurisdiction.
- Confirmed that PNB could independently pursue a separate collection case against respondents.