Case Summary (G.R. No. 127913)
Petitioner
Rizal Commercial Banking Corporation, holder of a consolidated title over the mortgaged property
Respondent
Metro Container Corporation, lessee of the subject property under lease with Ley Construction Corporation
Key Dates
• September 26, 1990 – LEYCON borrows ₱30 million from RCBC, mortgage on Valenzuela property
• December 28, 1992 – Extrajudicial foreclosure, RCBC highest bidder
• May 26, 1994 – LEYCON files unlawful detainer (MeTC Civil Case No. 6202) against METROCAN
• May 27, 1994 – METROCAN institutes interpleader (RTC Civil Case No. 4398-V-94) against LEYCON and RCBC
• July 4, 1995 – METROCAN and LEYCON settle; RTC dismisses interpleader as to them
• October 31, 1995 – MeTC orders METROCAN to pay LEYCON rentals; decision becomes final
• February 1, 1996 – METROCAN and LEYCON move to dismiss interpleader as moot; RTC denies motion (March 12, 1996)
• October 18, 1996 – CA grants METROCAN’s petition, sets aside RTC orders, dismisses interpleader
• January 8, 1997 – CA denies RCBC’s motion for reconsideration
• September 13, 2001 – Supreme Court promulgates decision
Applicable Law
• 1987 Philippine Constitution
• Rule 63, Revised Rules of Court (now Rule 62, Rules of Civil Procedure): interpleader action
Facts
Ley Construction Corporation mortgaged a Valenzuela property to RCBC for a ₱30 million loan. After Leycon defaulted, RCBC foreclosed extrajudicially in December 1992 and acquired title. Metro Container, originally leasing the property from Leycon, continued occupancy. RCBC demanded rental payments under its newly consolidated title; Metro Can hesitated, leading to competing claims by Leycon and RCBC over rent.
Proceedings Below
- Leycon’s unlawful detainer suit (MeTC No. 6202) sought possession and rentals from Metro Can.
- Metro Can’s interpleader (RTC No. 4398-V-94) named Leycon and RCBC to resolve conflicting claims to rental payments.
- After Metro Can and Leycon settled and MeTC ruled that Metro Can must pay Leycon rentals, Metro Can and Leycon moved to dismiss the interpleader as moot. The RTC denied these motions; appeals and petitions ensued.
- The Court of Appeals granted Metro Can’s certiorari petition, set aside the RTC orders, and dismissed the interpleader action. RCBC’s motion for reconsideration was denied.
Issue
Whether the final and executory MeTC judgment in the unlawful detainer case, directing Metro Can to pay Leycon the rentals, rendered the interpleader action moot and academic, justifying its dismissal despite RCBC’s contested ownership claim.
Interpleader Rule and Its Application
Under Rule 63, an interpleader protects a stakeholder claiming no interest or a non-disputed interest in the subject matter from vexation by conflicting claims. Metro Can filed interpleader because it was uncertain whether to pay Leycon (as contractual lessor) or RCBC (as title owner). The MeTC unlawful detainer decision, however, conclusively bound Metro Can to pay rentals to Leycon. That judgment resolved the very conflict over rental payments, el
...continue readingCase Syllabus (G.R. No. 127913)
Facts of the Case
- On 26 September 1990, Ley Construction Corporation (LEYCON) obtained a ₱30,000,000 loan from Rizal Commercial Banking Corporation (RCBC), secured by a real estate mortgage over a Valenzuela property (TCT No. V-17223).
- LEYCON defaulted on its obligations; RCBC initiated extrajudicial foreclosure and, on 28 December 1992, became the highest bidder.
- LEYCON filed Civil Case No. 4037-V-93 (Nullification of Extrajudicial Foreclosure Sale and Damages) in the RTC of Valenzuela, Branch 172.
- RCBC failed redemption; title consolidated in its name (TCT No. V-332432). RCBC then demanded rental payments from Metro Container Corporation (METROCAN), the lessee under LEYCON.
- On 26 May 1994, LEYCON sued METROCAN for unlawful detainer (Civil Case No. 6202) in the MeTC of Valenzuela, Branch 82.
- On 27 May 1994, METROCAN instituted an interpleader action against both LEYCON and RCBC (Civil Case No. 4398-V-94) in the RTC of Valenzuela, Branch 75, seeking determination of the rightful recipient of rental payments.
Procedural Posture in the Trial Courts
- During pre-trial on 4 July 1995 in Civil Case No. 4398-V-94, METROCAN and LEYCON were dismissed by amicable settlement: METROCAN paid back rentals to LEYCON.
- On 31 October 1995, the MeTC rendered judgment in Civil Case No. 6202 ordering METROCAN to pay LEYCON all due rentals; this decision became final and executory.
- On 1 February 1996, METROCAN and LEYCON separately moved to dismiss the interpleader (Civil Case No. 4398-V-94) as moot and academic; on 12 M