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Rule 62 Digests

The Wack Wack Golf & Country Club filed a complaint of interpleader against defendants Lee Won and Bienvenido Tan who both claimed ownership of the corporation's membership fee certificate 201. Won claimed ownership based on a court decision and certificate issued pursuant to that decision. However, the corporation argued the certificate violated its by-laws and the court decision did not bind Tan. The corporation requested an order for the defendants to interplead and determine the lawful owner of the certificate between themselves, and to surrender the cancelled certificate.

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0% found this document useful (0 votes)
263 views12 pages

Rule 62 Digests

The Wack Wack Golf & Country Club filed a complaint of interpleader against defendants Lee Won and Bienvenido Tan who both claimed ownership of the corporation's membership fee certificate 201. Won claimed ownership based on a court decision and certificate issued pursuant to that decision. However, the corporation argued the certificate violated its by-laws and the court decision did not bind Tan. The corporation requested an order for the defendants to interplead and determine the lawful owner of the certificate between themselves, and to surrender the cancelled certificate.

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Praxedes Alverez v.

Commonwealth
G.R. No. L-45315, February 25, 1938
Facts:
Plaintiffs alleged that they are bringing an action in behalf of themselves and 5 thousand other persons in that they are in
possession for many years of lots on which they now have their houses and agricultural land. These lands are found within Hacienda
de San Pedro Tunasan. They do not claim to be owners of the said lands but rather only of the improvements thereon. They allege that
they are entitled to occupy the same because it is where they have lived as well as their predecessors in interest and that they
recognize in favor of someone their obligation to pay reasonable rent over their occupation and that the true owner is the government
by virtue of escheat. This was acquired by the government through the death of Rodriguez de Figueroa without leaving any heir and his
2 minor daughters not leaving any heirs also. Colegio de San Jose and Carlos Young are claiming the estate.
However, defense alleged that Colegio de San Jose, through the Jesuits, had practiced Substitucion Pupilar and had
administered and managed the estate until they succeeded to appropriate the same, considering it as part of the temporal property of
the church. But after the Jesuits were expelled, it was confiscated by the Spanish government and after the Philippine government
passed laws, the ownership of such lands passed on to the current government and that the municipality of San Pedro has a right to a
hacienda for the exclusive benefit of its inhabitants; and that the Colegio de San Jose should render an accounting of the rentals which
it has been collecting from the hacienda, which should not be less than P60,000.
Issue #1 alleged that an interpleader is a petition, hence cannot be subject to demurrer.
The action of interpleader, under section 120, is a remedy whereby a person who has personal property in his possession, or an
obligation to render wholly or partially, without claiming any right in both, comes to court and asks that the persons who claim the said
personal property or who consider themselves entitled to demand compliance with the obligation, be required to litigate among
themselves, in order to determine finally who is entitled to one or the other thing. The remedy is afforded not to protect a person against
a double liability but to protect him against a double vexation in respect of one liability. When the court orders that the claimants litigate
among themselves, there arises in reality a new action and the former are styled interpleaders, and in such a case the pleading
which initiates the action is called a complaint of interpleader and not a cross-complaint. Hence, demurrer is proper.
Issue #2 alleged is that the interpleader is effective against the government despite it not giving its consent.
Philippine Commonwealth Government cannot be compelled to litigate without its consent, which also holds true in an
action for interpleader. There is no substantial difference between making it defend itself against it will in a case where it is a
defendant and compelling it, without its consent, to interplead in an action commenced by another person. In one and the other
case it is compelled, without its consent, to maintain a suit or litigation, and this is what the legal principal prohibits.

Issue #3 alleged that Colegio de San Jose, Municipality of San Pedro and the Government are contending over the right of collecting
the rents over the hacienda, hence interpleader proper.
An action of interpleader is indefensible from any standpoint for lack of the basis of reason relied upon by the plaintiffs in
their complaint, namely, that there are two entities, the Commonwealth of the Philippines and the Colegio de San Jose,
contending over the hacienda and claiming to be entitled to collect the rent or canon coming therefrom. Carlos Young is not
included because according to his own admission, he is a mere lessee of the Colegio de San Jose, Inc., and does not claim
any right of ownership adverse to the latter. It also appears from the allegations said complaint of interpleader that the municipality
of San Pedro also admits that the Commonwealth of the Philippine is the owner of the hacienda by transfer and right of
escheat.
Issue #4 has to do with the holding of the court that the complaint of interpleader of the municipality of San Pedro is premature
inasmuch as there has been no order yet that the defendant litigate among themselves.
In the opinion of the court it is necessary that there be a declaration to this effect before the defendant may litigate
among themselves and file a complaint of interpleader. Section 120 of the Code of Civil Procedure in truth requires such and good
practice demands that the defendants be not permitted to file claims or complaint of interpleader until after the court has ordered that
they should litigate among themselves. This procedure will do way with groundless suits, and will save the parties time, inconvenience,
and unnecessary expenses.
Ocampo v. Tirona
G.R. No. 147812, April 6, 2005
Facts:
Ocampo bought the subject parcel of land from Rosauro Breton, heir of the registered owner Alipio Breton Cruz. Tirona, tenant of
Breton, was informed of this arrangement and started paying Ocampo rent. Some months thereafter, Ocampo received a letter from
Callejo Law Office stating that Tirona will stop paying rent because the area has been declared under area for priority development.
Ocampo then wrote a demand letter for payment of rental. Despite receipt of said letter, Tirona failed and refused and still fails and
refuses to heed Ocampos demands.
Ocampo then filed a complaint for unlawful detainer and damages against Tirona before the MTC. Tirona answered by asserting
that Dona Yaneza was the owner, not Ocampo. Tirona subsequently filed a motion for leave to amend her answer because a lawyer did
not assist her in her initial answer. In her amended answer, Tirona maintained that Ocampo is not the owner of the subject land. Tirona
also alleged that she has a right of first refusal in case of sale of the land.

MTC ruled in favor of Ocampo because of non-payment of rent and because of the termination of Tironas right to possess and
occupy the subject land. Tirona changed theory in the RTC and raised that it was Rosauros sister Ma. Lourdes who could validly sell
the land to Ocampo. The court did not believe her and still ruled in favor of Ocampo. CA considered partition of the estate of Alipio as a
prerequisite to Ocampos action so it reversed the decision of the MTC and RTC.
Issue:
Who has the right of possession of the subject land? What should have been filed by Tirona to show good faith of Tirona in not paying
rent?
Ruling:
Ocampo has a better right. All the elements of unlawful detainer are present. Tirona obviously is in bad faith. The good faith of
Tirona is put in question in her preference for Maria Lourdes Breton-Mendiola when Ocampo informed her earlier that the land has
already been sold to him. As a stakeholder, Tirona should have used reasonable diligence in hailing the contending claimants
to court. Tirona need not have awaited actual institution of a suit by Ocampo against her before filing a bill of interpleader . An
action for interpleader is proper when the lessee does not know the person to whom to pay rentals due to conflicting claims
on the property
Note: The action of interpleader is a remedy whereby a person who has property whether personal or real, in his possession, or an
obligation to render wholly or partially, without claiming any right in both, or claims an interest which in whole or in part is not disputed
by the conflicting claimants, comes to court and asks that the persons who claim the said property or who consider themselves entitled
to demand compliance with the obligation, be required to litigate among themselves, in order to determine finally who is entitled to one
or the other thing. The remedy is afforded not to protect a person against a double liability but to protect him against a double vexation
in respect of one liability. When the court orders that the claimants litigate among themselves, there arises in reality a new action and
the former are styled interpleaders, and in such a case the pleading which initiates the action is called a complaint of interpleader and
not a cross-complaint
Wack Wack Golf v. Won
G.R. No. L-23851, March 26, 1976
Facts:
Wack Wack Golf & Country Club (Corporation), a non-stock, civic and athletic corporation organized under the laws of the
Philippines, filed a complaint of interpleader. It alleged, for its first cause of action, that defendants Lee Won and Bienvenido Tan were
both claiming ownership over the Corporations membership fee certificate (MFC) 201: Won, by virtue of the decision of the CFI of
Manila in civil case 26044 and by MFC 201-serial no. 1478 issued on Oct. 17, 1963 by the deputy clerk of court for and in behalf of the
president and secretary of the corporation and of the Peoples Bank & Trust Company; Tan, on the other hand, by virtue of MFC 201serial no. 1199 issued on July 24, 1950 pursuant to an assignment in his favor by Swan, Culbertson and Fritz, the original owner of

MFC 201. For its second cause of action, the Corporation alleged that MFC 201-serial no. 1478 issued by the deputy clerk of court in
behalf of the Corporation is null and void because it was issued in violation of the Corporations by-laws, which require the surrender
and cancellation of the outstanding MFC 201 before issuance may be made to the transferee of a new certificate duly signed by its
president and secretary, aside from the fact that the decision of the CFI of Manila in civil case 26044 is not binding upon defendant Tan.
The Corporation prayed for the issuance of an order requiring Lee and Tan to interplead and litigate their conflicting claims,
declaring who the lawful owner of MFC 201 is, and ordering the surrender and cancellation of MFC 201-serial no. 1478 issued in the
name of Lee.
The trial court dismissed the complaint upon motion of the defendants on the grounds of res judicata, failure of the complaint to
state a cause of action, and bar by prescription.
Issue:
Whether or not the action of interpleader was proper and timely filed.
Ruling:
No. The Supreme Court affirmed the dismissal of the complaint.
The action of interpleader, under 120 of the Code of Civil Procedure, is a remedy whereby a person who has personal property
in his possession, or an obligation to render wholly or partially, without claiming any right to either, comes to court and asks that the
persons who claim the said personal property or who consider themselves entitled to demand compliance with the obligation, be
required to litigate among themselves in order to determine finally who is entitled to tone or the one thing. The remedy is afforded to
protect a person not against double liability but against double vexation in respect of one liability.
A stakeholder should use reasonable diligence to hale the contending claimants to court. He need not await actual institution of
independent suits against him before filing a bill of interpleader. He should file an action of interpleader within a reasonable time after a
dispute has arisen without waiting to be sued by either of the contending claimants. Otherwise, he may be barred by laches or undue
delay. But where he acts with reasonable diligence in view of the environmental circumstances, the remedy is not barred.
If a stakeholder defends a suit filed by one of the adverse claimants and allows said suit to proceed to final judgment against
him, he cannot later on have that part of the litigation repeated in an interpleader suit. In the case at hand, the Corporation allowed civil
case 26044 to proceed to final judgment. And it offered no satisfactory explanation for its failure to implead Tan in the same litigation. In
this factual situation, it is clear that this interpleader suit cannot prosper because it was filed much too late.
A successful litigant cannot later be impleaded by his defeated adversary in an interpleader suit and compelled to prove his claim
anew against other adverse claimants, as that would in effect be a collateral attack upon the judgment.

In fine, the interpleader suit cannot prosper because the Corporation had already been made independently liable in civil case
26044 and, therefore, its application for interpleader would in effect be a collateral attack upon the final judgment in the said civil case;
Lee had already established his rights to MFC 201 in the civil case and, therefore, this interpleader suit would compel him to establish
his rights anew, and thereby increase instead of diminish litigations, which is one of the purposes of an interpleader suit, with the
possibility that the benefits of the final judgment in the said civil case might eventually be taken away from him; and because the
Corporation allowed itself to be sued to final judgment in the said case, its action of interpleader was filed inexcusably late, for which
reason it is barred by laches or unreasonable delay.
Ramos v. Ramos
G.R. No. 144294, March 11, 2003
Facts:
Petitioners are children of the late Paulino V. Chanliongco, Jr., who was the co-owner of a parcel of land in Tondo. The other coowners were his siblings: Narcisa, Mario and Antonio. By virtue of a SPA executed by the co-owners in favor of Narcisa, her daughter
Adoracion had sold the lot to respondents. Because of the conflict among the heirs of the co-owners as to the validity of the sale,
respondents filed with the RTC a Complaint for Interpleader to resolve the various ownership claims.
The RTC upheld the sale insofar as the share of Narcisa was concerned. It ruled that Adoracion had no authority to sell the
shares of the other co-owners, because the SPA had been executed in favor only of her mother Narcisa. The CA held that the sale was
valid. This 1995 decision was not appealed; it became final. In 1999, petitioners filed with the CA a Motion to Set Aside the Decision,
contending that they had not been served a copy of either the Complaint or the summons, nor been impleaded as parties to the case.
CA denied their motion.
Issue:
W/N the CA erred in denying petitioners motion and allowing its decision to take its course, inspite of its knowledge that the lower court
did not acquire jurisdiction over the person of petitioners and passing petitioners property in favor or respondents, hence without due
process of law.
Ruling:
The Complaint filed by respondents with the RTC called for an interpleader to determine the ownership of the real property in
question. Specifically, it forced persons claiming an interest in the land to settle the dispute among themselves as to which of them
owned the property. Essentially, it sought to resolve the ownership of the land and was not directed against the personal liability of any
particular person. It was therefore a real action, because it affected title to or possession of real property. As such, the Complaint was
brought against the deceased registered co-owners, as represented by their respective estates.
Clearly, petitioners were not the registered owners of the land, but represented merely an inchoate interest thereto as heirs of
Paulino. They had no standing in court with respect to actions over a property of the estate, because the latter was represented by an

executor or administrator. Thus, there was no need to implead them as defendants in the case, inasmuch as the estates of the
deceased co-owners had already been made parties.
Under the former rules (when the complaint was filed), an executor or administrator is allowed to either sue or be sued alone in
that capacity. In the present case, it was the estate of petitioners father Paulino, as represented by Sebrio Tan Quiming and Associates
that was included as defendant and served summons. As it was, there was no need to include petitioners as defendants. Not being
parties, they were not entitled to be served summons.
Makati Development Corp v. Tanjuatco
G.R. No. L-26443, March 25, 1969
Facts:
Plaintiff Makati Devt Corp and defendant Tanjuatco entered into a contract whereby the latter bound himself to construct a
reinforced concrete covered water reservoir, office and pump house and water main at Forbes Park, furnishing the materials necessary
therefor. Before making the final payment of the consideration agreed upon, plaintiff inquired from the suppliers of materials, who had
called its attention to unpaid bills of Tanjuatco, whether the latter had settled his accounts with them. In response to this inquiry,
Concrete Aggregates, Inc. (supplier) made a claim in the sum of P5,198.75, representing the cost of transit-mixed concrete allegedly
delivered to Tanjuatco. With his consent, plaintiff withheld said amount from the final payment made to him and, in view of his
subsequent failure to settle the issue thereon with the Supplier, plaintiff instituted the present action against Tanjuatco and the Supplier,
to compel them "to interplead their conflicting claims."
Tanjuatco moved to dismiss the case, upon the ground that the court had no jurisdiction over the subject-matter of the litigation, the
amount involved therein being less than P10,000.00. The lower court granted the same and dismissed the case. Hence, this appeal.
Plaintiff contends that the CFI has jurisdiction because the subject-matter of this litigation is not the aforementioned sum of P5,198.75,
but the right to compel the defendants "to litigate among themselves".
Issue:
Does the CFI have jurisdiction over the case?
Held:
No. Plaintiff may compel the defendants to interplead among themselves concerning the aforementioned sum of P5,198.75. The issue
of who among the defendants is entitled to collect the same is the object of the action and is not within the jurisdiction of the CFI.
The plaintiff in asserting the jurisdiction of the CFI relies upon Rule 63 of the present Rules of Court, prescribing the procedure in cases
of interpleading, and section 19 of Rule 5, which omits the Rules on Interpleading among those made applicable to inferior courts.
However, the jurisdiction of our courts over the subject-matter of justiciable controversies is governed by Rep. Act No. 296, as
amended, pursuant to which municipal courts shall have exclusive original jurisdiction in all civil cases "in which the demand, exclusive
of interest, or the value of the property in controversy", amounts to not more than PHP10,000. Secondly, "the power to define,

prescribe, and apportion the jurisdiction of the various courts" belongs to Congress and is beyond the rule-making power of the
Supreme Court, which is limited to matters concerning pleading, practice, and procedure in all courts, and the admission to the practice
of law. Thirdly, the failure of said section 19 of Rule 5 of the present Rules of Court to make its Rule 63, on interpleading, applicable to
inferior courts, merely implies that the same are not bound to follow Rule 63 in dealing with cases of interpleading, but may apply
thereto the general rules on procedure applicable to ordinary civil action in said courts.
Sy-Quia v. Sheriff of Ilocos Sur
G.R. No. L-22807, October 10, 1924
Facts:
This is a petition for a writ of mandamus to compel the Sheriff of Ilocos Sur to proceed with a chattel mortgage foreclosure sale.
On 3 Feb 1915, Cheng-Laco and Cheng-Kiangco executed a chattel mortgage in favor of the petitioner, Sy-Quia on their mercantile
establishment, including the merchandise therein, as security for a 6k debt. The mortgage was recorded on the date of its execution
and fell due on 3 Feb 1917. An agreement was made that the mortgagors were allowed to sell the merchandise replenishing their stock
and that the new stock brought in should also be subject to the mortgage.
On 5 May 1924, Cheng-Laco executed another chattel mortgage on the same establishment and all its contents in favor of the
respondent De Leon (De Leon) as security for the sum of P4,900, which mortgage was recorded on 4 May 1924.
The petitioner, in writing, requested the sheriff to take possession of the mortgaged property and to sell it at public auction under
Sec. 14 of the Chattel Mortgage Law (Act No. 1508). The sheriff seized the establishment and fixed the date of the sale on 2 June
1924. Afterwards, De Leon presented an adverse claim to the property by virtue of his chattel mortgage, alleging that all the goods on
which the chattel mortgage of Sy-Quia was given had been sold long before the chattel mortgage in favor of De Leon was executed and
that the earlier chattel mortgage was of no effect.
The sheriff, in doubt as to the conflicting claims, suspended the foreclosure proceedings and brought an action under section 120
of the Code of Civil Procedure requiring the two claimants to interplead.
Issue:
W/N the sheriff was correct in suspending the sale and bringing an action requiring the 2 claimants to interplead
Ruling:
YES. Court held that it wouldve been better practice for the sheriff to sell the property and hold the proceeds of the sale subject
to the outcome of the action of interpleader, the court would still not justify interference by mandamus. The sheriff might lay himself

open to an action for damages if he sold the goods without the consent of the holder of the last mortgage, and it does not appear that
the petitioner offered to give bond to hold him harmless in such an event. His action in suspending the sale pending the determination
of the action of interpleader seems justified.
In cases like this, the petition for mandamus should be addressed to the Courts of First Instance rather than to this court. The
petition is denied with the costs against the petitioner.

Mesina v. IAC
G.R. No. 70145, November 13, 1986
FACTS:
Jose Go (Go) purchased from Associated Bank (AB) Cashier's Check No. 011302 for P800,000.00. Unfortunately, Go left said
check on the top of the desk of the bank manager when he left the bank. The bank manager entrusted the check for safekeeping to a
bank official, a certain Albert Uy (Uy), who had then a visitor in the person of Alexander Lim (Lim).
Uy had to answer a phone call on a nearby telephone after which he proceeded to the men's room. When he returned to his
desk, his visitor Lim was already gone, along with the check. Uy advised Go to go to the bank to accomplish a "STOP PAYMENT" order.
Uy also made a police report, pointing to the person of Alexander Lim as the one who could shed light on it.
Police records that AB received the lost check for clearing on December 31, 1983, coming from Prudential Bank (PB) Escolta
Branch. The check was immediately dishonored by AB and sent it back to PB, with "Payment Stopped" stamped on it. 4 days thereafter,
the same was again returned to AB. Yet again, AB dishonored it. Several days later, AB received a letter from Atty. Lorenzo Navarro
(Atty. Navarro) demanding payment on the cashier's check being held by his client, whose name he refused to reveal. Atty. Navarro
threatened to sue if payment is not made
AB in its letter replied saying the check belonged to Go who lost it in the bank and is laying claim to it. The police sent a letter to
the Manager of the PB requesting assistance in identifying the person who tried to encash the check, but it refused. PB said it had to
protect its client's interest and the identity could only be revealed with the client's conformity.
Unsure of what to do on the matter AB filed an action for Interpleader naming as Go and John Doe, Atty. Navarro's unnamed
client. AB received summons and copy of the complaint for damages of Marcelo A. Mesina (Mesina) from the RTC of Caloocan City.
AB moved to amend its complaint, having been notified for the first time of the name of Atty. Navarro's client and substituted Mesina for
John Doe. Simultaneously, AB thru representative Uy, informed Cpl. Gimao of the Western Police District that the lost check of Go is in
the possession of Mesina. Cpl. Gimao went to Mesina to inquire on how he had possession of the check. Mesina answered that it was
paid to him by Lim in a "certain transaction" but refused to elucidate further.

An information for theft and warrant of arrest was issued to Lim. (said warrant up to the date of the filing of this petition remains
unserved since Lim couldnt be found). Meanwhile, Go filed his answer in the Interpleader Case and moved to participate as intervenor
in the complaint for damages. Uy also filed a motion of intervention and answer in the complaint for Interpleader. During pre-trial
conference in the interpleader case, it was disclosed that the "John Doe" is actually Mesina. Mesina, instead of filing his answer to the
complaint in the interpleader, filed on an Omnibus Motion to Dismiss Ex Abudante Cautela alleging lack of jurisdiction in view of the
absence of an order to litigate, failure to state a cause of action and lack of personality to sue.
TC DECISION ON INTERPLEADER: ordered AB to replace Cashier's Check in favor of Go or its cash equivalent with legal rate of
interest from date of complaint.
ISSUE:
Whether or not interpleader suit is proper
HELD:
YES. Decision affirmed in toto.
Mesina insists that there is no showing of conflicting claims; thus, interpleader is out of the question. However, AB merely took the
necessary precaution not to make a mistake as to whom to pay and therefore interpleader was its proper remedy.
It has been shown that the interpleader suit was filed by AB because Mesina and Go were both laying their claims on the check. Mesina
was even asking payment thereon and Go as the purchaser or owner.
AB filed the interpleader suit not because petitioner sued it but because Mesina is laying claim to the same check that Go is claiming.
On the very day AB instituted the case in interpleader, it was not aware of any suit for damages filed by Mesina against it as supported
by the fact that the interpleader case was first entitled Associated Bank vs. Jose Go and John Doe.
THUS, records of the case show that AB had to resort to details in support of its action for Interpleader. Before even resorting to
Interpleader, AB took precautionary and necessary measures to bring out the truth.
Vda. De Camilo v. Arcamo
G.R. No. 15653, September 29, 1961
Facts:
Petitioner Petra had been in peaceful, open and adverse possession of a parcel of public foreshore land situated in Malangas,
Zamboanga del Sur. A commercial building was erected on said property and respondent Ong Peng Kee was a lessee of one of the
apartments of said commercial building. Bannister filed an unlawful detainer case against both De Camilo and Kee but for his failure to
appear at the trial, he was declared in default. Petitioners Franciscos had also been in possession, peaceful, open and adverse of a
parcel of public foreshore land, adjoining that land occupied by De Camilo. On this parcel, a commercial building was erected by the

Franciscos. The two commercial buildings were burned down. Two weeks thereafter, respondents Kee and Ong, constructed a building
of their own which was so built that portions of the lands previously occupied by petitioners were encroached upon.
De Camilo filed a case for Forcible Entry against the respondents with respect to portion belonging to her wherein the building of Kee
was erected. The Franciscos filed a similar case. The respondents claimed that the land where they constructed their building was
leased to them by the Municipality of Malangas. Pending trial of the two cases, the respondents filed a complaint for Interpleader
against De Camilo, Estrada, the Franciscos, Bannister, the Mayor and Treasurer of Malangas, alleging that the filing of the cases of
forcible entry, indicated that the defendants in the Interpleader had conflicting interests, since they all claimed to be entitled to the
possession of the lot in question and they (Kee and Ong) could not determine without hazard to themselves who of defendants was
entitled to the possession. Interpleader plaintiffs further alleged that they had no interest in the property other than as mere lessees.
Herein petitioners filed a motion to dismiss the complaint for Interpleader but the same was denied and they were ordered to interplead.
Petitioners instituted the present proceedings for certiorari and mandamus, against Justice of peace Arcamo and herein respondents.
They allege that Arcamo gravely abused his discretion in giving due course to the complaint for interpleader, and that he unlawfully
neglected the performance of an act which was specifically enjoined by law, and for which there was no plain, speedy and adequate
remedy in the ordinary course of law. The CFI ruled that Arcamo had no jurisdiction to try the case of interpleader.
Issue:
Was the filing of the interpleader proper? Does the Justice of the Peace Court have jurisdiction to take cognizance of the Interpleader
case?
Held:
No to both. Section 1, Rule 14 provides that an Interpleader is proper whenever conflicting claims upon the same subject matter
are or may be made against a person, who claims no interest whatever in the subject-matter, or an interest which in whole or in part is
not disputed by the claimants, such person may bring an action against the conflicting claimants to compel them to interplead and
litigate their several claims among themselves.
The petitioners did not have conflicting claims against the respondents. Their respective claim was separate and distinct from the other.
De Camilo only wanted the respondents to vacate that portion of her property which was encroached upon by them when they erected
their building. The same is true with Estrada and the Franciscos. They claimed possession of two different parcels of land of different
areas, adjoining each other. Furthermore, it is not true that respondents did not have any interest in the subject matter. Their interest
was the prolongation of their occupancy or possession of the portions encroached upon by them. It is, therefore, evident that the
requirements for a complaint of Interpleader do not exist.
The complaint asking the petitioners to interplead, practically took the case out of the jurisdiction of the JP court, because the action
would then necessarily "involve the title to or possession of real property or any interest therein" over which the CFI has original

jurisdiction. Then also, the subject matter of the interpleader would come under the original jurisdiction of the CFI, because it would not
be capable of pecuniary estimation, there having been no showing that rentals were asked by the petitioners from respondents.
Beltran v. Peoples Homesite
G.R. No. 25138, August 28, 1969
Facts:
An interpleader suit was filed on August 21, 1962, by plaintiffs Jose Beltran, et al. in their own behalf and in behalf of all residents
of Project 4 in Quezon City, praying that the People's Homesite & Housing Corporation (PHHC) and GSIS be compelled to litigate and
interplead between themselves their alleged conflicting claims involving said Project 4.
PHHC leased out housing units to plaintiffs in 1953. The lessees, paying monthly rentals therefor, were assured by competent authority
that after 5 years of continuous occupancy, they would be entitled to purchase these units. In 1961, the PHHC announced that the
management, administration and ownership of Project 4 would be transferred to GSIS in payment of PHHS debts to GSIS. PHHC also
asked the tenants to signify their conformity to buy the housing units at the selling price indicated on the back thereof, agreeing to credit
the tenants, as down payment on the selling price, 30% of what had been paid by them as rentals. The tenants accepted the PHHC
offer, and on March 27, 1961, the PHHC announced in another circular that all payments made by the tenants after March 31, 1961
would be considered as amortizations or installment payments.
By the end of 1960, administration and ownership of Project 4 was turned over to GSIS. PHHC, however, through its new ChairmanGeneral Manager, Esmeraldo Eco, refused to recognize all agreements previously entered into with GSIS, while GSIS insisted on its
legal rights to enforce the said agreements and was upheld in its contention by both the Government Corporate Counsel and the
Secretary of Justice.
Plaintiffs thus claimed that these conflicting claims between PHHC and GSIS caused them great inconvenience and incalculable moral
and material damage, as they did not know to whom they should pay the monthly amortizations or payments.
TC: Designated the People's First Savings Bank, QC "to receive in trust the payments from the plaintiffs on their monthly amortizations
on PHHC lots and to be released only upon proper authority of the Court."
PHHC and GSIS filed a Motion to Dismiss the complaint of Beltran, et al. for failure to state a cause of action as well as to lift the
Court's order designating the People's First Savings Bank as trustee to receive the tenants' payments on the PHHC lots.

TC granted the Motion, ruling that the counsel for GSIS ratified the allegations in his motion and made of record that GSIS has no
objection that payments on the monthly amortizations be made directly to PHHC. There was thus no dispute as to whom the residents
pay and therefore no cause of action for interpleading. Counsel for defendants went further to say that whatever dispute, if any, may
exist between the two corporations over the lots and buildings in Project 4, payments made to the PHHC will not and cannot in any way
affect or prejudice the rights of the residents thereof as they will be credited by either of the two defendants.
On appeal, plaintiffs claim that the trial Court erred in dismissing their suit, contending the allegations in their complaint "raise questions
of fact that can be established only by answer and trial on the merits and not by a motion to dismiss heard by mere oral manifestations
in open court," and that they "do not know who, as between the GSIS and the PHHC, is the right and lawful party to receive their
monthly amortizations as would eventually entitle them to a clear title to their dwelling units."
Issue:
Whether the dismissal of the complaint for interpleader was proper? YES.

Ruling:
Plaintiffs entirely missed the vital element of an action of interpleader. Rule 62, section 1 of the Revised Rules of Court requires
as an indispensable element that "conflicting claims upon the same subject matter are or may be made" against the plaintiff-ininterpleader "who claims no interest whatever in the subject matter or an interest which in whole or in part is not disputed by the
claimants." While PHHC and GSIS may have conflicting claims between themselves with regard to the management, administration
and ownership of Project 4, such conflicting claims are not against the plaintiffs nor do they involve or affect the plaintiffs. No allegation
is made in their complaint that any corporation other than the PHHC which was the only entity privy to their lease-purchase agreement,
ever made on them any claim or demand for payment of the rentals or amortization payments. The questions of fact raised in their
complaint concerning the enforceability, and recognition or non-enforceability and non-recognition of the turnover agreement of
December 27, 1961 between the two defendant corporations are irrelevant to their action of interpleader, for these conflicting claims,
loosely so-called, are between the two corporations and not against plaintiffs. Both defendant corporations were in conformity and had
no dispute, as pointed out by the trial court that the monthly payments and amortizations should be made directly to the PHHC alone.

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