JOSE

A.
BELTRAN,
ET
AL., plaintiffs-appellants,
vs.
PEOPLE'S HOMESITE & HOUSING CORPORATION, defendantsappellees.
G.R. No. L-25138
August 28, 1969
Teehankee, J:
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 plaintiffin-interpleader "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 nonrecognition 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.
Board of Optometry vs. Hon. Colet
G.R. No.
122241 July 30, 1996
Facts:
The Revised Optometry Law of 1995 was approved into law. The
private respondents here filed with the RTC for a declaratory relief,
among others, to protect their Constitutional rights because
allegedly, said law would affect their operation and inflict serious
and irreparable injury to their legal rights. They were not able to
prove, however, their juridical personality. Thus, they also assert

that such action is in their capacity as taxpayers and citizens suit,

and therefore pray to bar the enforcement of the law because it
endangers public health (in the nature of a taxpayers suit).
Issue: WON the private respondents have a legal interest in the
controversy; and WON the issue invoked is ripe for judicial
determination.
Held: No and no.
As a special civil action for declaratory relief, its requisites are: (1)
the existence of a justiciable controversy; (2) the controversy is
between persons whose interests are adverse; (3) that the party
seeking the relief has a legal interest in the controversy; and (4)
that the issue invoked is ripe for judicial determination. On this
score, we find no difficulty holding that at least the first and fourth
requisites are wanting.
For having failed to show that they are juridical entities, private
respondents must then be deemed to be devoid of legal personality
to bring the action. Thus, they cannot be deemed real parties in
interest. They cannot also claim such legal personality under a
taxpayers suit because, among others, they failed to allege the
existence and prove the requisites of a class suit.
And since an actual case or controversy means an existing case or
controversy that is appropriate or ripe for determination, not
conjectural or anticipatory, it cannot be disputed that there is yet
no actual case or controversy involving all or any of the private
respondents on one hand, and all or any of the petitioners on the
other, with respect to rights or obligations under the law subject
matter of this case.
OLLADA VS. CENTRAL BANK
Facts: Felipe B. Ollada is a certified public accountant, accredited
to practice accountancy in the office of the Central Bank of the
Philippines. In December 1955, by reason of a requirement of the
Import-Export Department of said bank that CPAs submit to an
accreditation under oath before they could certify financial
statements of their clients applying for import dollar allocations
with its office, Ollada's previous accreditation was nullified. Ollada
thus filed a petition for declaratory relief before the trial court to
nullify said accreditation requirement. He alleges that because of
these requirements he had suffered serious injury, and that such
enforcement has resulted in the unlawful restraint in the practice of
CPAs in the Office of the Central Bank.
Issue: Will

the

petition

for

declaratory

relief

prosper?

Held: The complaint for declaratory relief will not prosper if filed
after a contract, statute or right has been breached or violated. In
the present case such is precisely the situation arising from the
facts alleged in the petition for declaratory relief. As vigorously
claimed by petitioner himself, respondent had already invaded or
violated his right and caused him injury all these giving him a
complete cause of action enforceable in an appropriate ordinary
civil
action
or
proceeding.
An action for declaratory relief should be filed before there has

been a breach of a contract, statutes or right, and that it is

sufficient to bar such action, that there had been a breach which
would constitute actionable violation. The rule is that an action for
Declaratory Relief is proper only if adequate relief is not available
through the means of other existing forms of action or
proceeding. (Ollada vs. Central Bank, G.R. No. L-11357, May 31,
1962)