INTERPLEADER

1 WACK WACK GOLF v. WON/LEE and TAN

FACTS:
Wack Wack alleged the following for its first cause of action:
1. Won aka Lee claims ownership of a membership
certificate of Wack Wack Golf by virtue of a civil case
(Lee v. Wack Wack) decision in his favor.
2. Tan is also claiming ownership over the same
certificate pursuant to an assignment in his favor by
the original owner.
For its second cause of action:
1. The certificate issued by the Clerk of Court in behalf of
Wack Wack (referring to the civil case where Lee got
the certificate) is null and void for violation of its bylaws which require the surrender and cancellation of
an outstanding certificate before it could be
transferred.
2. Tan is made a party because he refused to join Wack
Wacks action or bring a separate action to protect his
rights.
PROCEDURAL FACTS:
1. Wack Wack filed a complaint for interpleader and
prayed that an order be issued requiring Lee and Tan
to interplead and for the Court to declare who is the
lawful owner of the certificate.
2. Lee and Tan moved to dismiss on the grounds of res
judicata, failure to state cause of action, and
prescription.
3. TC: Dismissed Wack Wacks complaint based on res
judicata and failure to state CoA.
4. Wack Wack appealed: No res judicata because there is
no identity of parties, subject matter and cause of
action with the civil case.
ISSUE: Whether the remedy of interpleader is proper and
timely. NO.
RATIO:

An action of interpleader 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 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 to protect a person not against
double liability but against double vexation in respect of
one liability.
An interpleader suit is proper on if the subject-matter is
personal property or related to the performance of an
obligation.
o The subject matter for this case, membership fee
certificate, is proper for an interpleader suit.
A stakeholder should file an action for interpleader within
a reasonable time after a dispute has arisen without
waiting to be sued, otherwise, he may be barred by laches
and delay.
o If he acts with reasonable diligence, the
remedy is not barred.
In this case, there was no reasonable diligence because
Wack Wack was aware of the conflicting claims long
before it filed an interpleader suit.
o It has been recognizing Tan as the lawful owner.
o It was sued by Lee who also claimed the same
certificate.
o Yet, it did not interplead Tan. It proceeded to litigate
(civil case) and to defend itself.
o Final judgment therein already became executory.
o TOO LATE TO INVOKE INTERPLEADER AS REMEDY.
A stakeholders action of interpleader is too late when
filed after judgment has been rendered against him in
favor of one of the contending claimants, especially where
he had notice of the conflicting claims prior to the
rendition of the judgment and neglected the opportunity
to implead the adverse claimants in the suit where
judgment was entered.

Wack Wack was already liable to Lee under a final

judgment when he filed the interpleader.
He also did not offer any explanation for its failure to
implead Tan in the civil case.
A successful litigant cannot later be impleaded by his
defeated adversary in an interpleader suit and compelled
to prove his claim again because that would be a
collateral attack upon the judgment.

2 RCBC v. METRO CONTAINER CORPORATION

FACTS:
1. Ley Construction (LeyCon) contracted a loan from
RCBC (P30M). The loan was secured with a REM over a
property in Valenzuela.
a. LeyCon failed to settle the obligation. Property
was foreclosed, RCBC won as highest bidder.
b. LeyCon filed for nullification.
c. Meanwhile, a new TCT was issued in RCBCs
favor due to LeyCons failure to redeem it.
2. RCBC then demanded rental payments from Metro
Container (MetroCan) which was leasing the property
from LeyCon.
3. LeyCon filed an action for Unlawful Detainer against
MetroCan. (Case 1)
4. MetroCan filed a complaint for Interpleader against
Leycon and RCBC to determine which one should
rightfully receive the payment of monthly rentals.
(Case 2)
5. Pre-trial, TC: Dismissed Case 2 for MetroCan and
Leycon; amicable settlement.
6. Case 1, TC: MetroCan ordered to pay LeyCon. This
decision became final and executory.
7. MetroCan moved for the dismissal of Case 2 for having
been moot and academic due to the amicable
settlement. Leycon also moved for dismissal, same
grounds.
8. The MTDs were dismissed for lack of merit. MRs also
denied.
9. CA: Ordered the dismissal of Case 2. RCBC moved for
reconsideration, denied.
ISSUE: Whether the interpleader action was already moot
and academic. YES.
RATIO:
LeyCon was claiming payment of rentals as lessor while
RCBC was making a demand by virtue of the consolidation
of its title.

The reason for the interpleader action ceased when MTC

rendered a decision directing MetroCan to pay LeyCon.
o While RCBC is not a party to the case and could not
be bound by the judgment, MetroCan is bound by
the decision.
o When it became executory, MetroCan has no other
alternative left but to pay the rentals to LeyCon.
MetroCan moved for the dismissal of the interpleader not
because it is no longer interested but because there is no
more need for it to pursue such cause of action.
An action of interpleader is afforded to protect a person
not against double liability but against double vexation in
respect of one liability.
o Indispensable requisite that conflicting claims upon
the same subject matter are made against the
plaintiff-in-interpleader who claims no interest
whatever in the subject matter or an interest which
is not disputed by the claimants.
o The decision in Case 1 resolved the conflicting
claims insofar as payment of rentals was
concerned.
RCBC is correct in saying that it is not bound by the
decision in Case 1 for not being a party thereto. But, it
could not compel MetroCan to pursue Case 2.

3 LIM v. CONTINENTAL DEVELOPMENT

FACTS:
1. Continental Development Corp. filed a complaint for
interpleader against Tan and Lim.
a. In CDCs book, Tan is a stockholder of the
company.
b. Tan has been demanding for the release of the
certificates of stock but CDC refused because of
an adverse claim by Lim.
c. Lim had been persistent in claiming the very
same shares of stock demanded by Tan saying
that these stocks belonged to her mother, now
deceased.
d. Both Tan and Lim threatened to take measures
against CDC to protect their interest.
2. CDC wants to determine to whom it should deliver the
certificates.
a. Stressed that it might be liable to one should it
comply with the demands of the other.
3. Tan moved to dismiss on the ground that in CDCs
books, Tan is the recorded owner and therefore he
should get the certificates.
4. Lim: The stocks has been delivered in trust to Tan for
Lims mother, the actual owner of the stocks.
5. TC: Dismissed the complaint for lack of cause of action.
ISSUE: Whether the action for interpleader was proper. YES.
RATIO:
Since there is an active conflict of interests between two
defendants, the TC gravely abused its discretion in
dismissing the complaint for interpleader, which
practically decided ownership of the stocks in favor of Tan.
The two defendants must be given full opportunity to
litigate their respective claim.
Rule 63, Sec. 1: 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, he may bring an action against

the conflicting claimants to compel them to interplead

and litigate their several claims among themselves.
This provision requires that the conflicting claims upon the
same subject matter are made against the plaintiff-ininterpleader who claims no interest whatever in the
subject matter or an interest is not disputed by the
claimants.
An interpleader merely demands that two or more
persons claim to the fund or thing in dispute through
separate and different interests.
Petition for interpleader granted.

4 ARREZA v. DIAZ
FACTS:
1. Bliss Development is the owner of a housing unit in
QC.
2. A case was instituted involving the conflict of
ownership between Arreza and Diaz.
3. Bliss filed a complaint for interpleader.
4. TC: Interpleader is resolved in favor of Arezza. This
became final and duly executed with Bliss executing a
Contract to Sell to Arezza. Diaz was constrained to
deliver the property with all its improvements to
Arreza.
5. Diaz filed a complaint against Bliss and Arreza seeking
to hold them liable to reimburse the cost of acquisition
and improvements on the property.
6. Arezza, MTD: Res judicata (interpleader case already
resolved) and lack of cause of action. Denied.
Reconsideration.
7. CA: Dismissed Arezzas MR. The decision invoked as
res judicata resolved only the issue of who between
Arezza and Diaz has the better right over the property
but not the rights and obligations of the parties.
ISSUE: Whether Diazs claims for reimbursement against
Arezza are barred by res adjudicata since the complaint for
interpleader had already been resolved. YES.
RATIO:
Elements for res adjudicata:
o Former judgment must be final
o Court which rendered judgment has jurisdiction
over the parties and the subject matter
o Must be a judgment on the merits
o There must be between the 1 st and 2nd causes of
action identity of parties, subject matter, and cause
of action.
The prior case for interpleader was settled with finality.
The judgment therein is now final.
RTC acquired jurisdiction over the parties and subject
matter.

Diazs contention that the TC did not acquire

jurisdiction (property is in QC, action was instituted
in Makati) is wrong. When he asserted his right as a
buyer for value and in good faith, and asking relief
arising therefrom, he invoked the jurisdiction of the
RTC. Having invoked it by filing answer, he is now
estopped from challenging its jurisdiction.
There is an identity of causes of action.
o Diazs cause of action was in the nature of an
unpleaded compulsory counterclaim.
There being a former final judgment on the merits in the
prior case, the case (for reimbursement) before the court
should be dismissed on the ground of res adjudicata.
o

5 SY-QUIA v. SHERIFF OF ILOCOS SUR and DE LEON

FACTS:
1. Laco and ChengKiango executed a chattel mortgage in
favor of Sy-Quia on their mercantile establishment,
with all the merchandise therein, as a security for a
debt (P6k).
2. From its terms, it may be inferred that it was the
parties intention that the mortgagors were permitted
to sell the merchandise, replenish them, and the new
stock be also subject to the mortgage.
3. Laco executed another chattel mortgage on the same
establishment and all its contents in favor of De Leon
as security for a debt.
4. Sy-Quia later requested the sheriff to take possession
of the mortgaged property and to sell it at public
auction.
5. The sheriff seized the establishment and its contents.
6. De Leon presented an adverse claim to the property by
virtue of the chattel mortgage. He said that all the
goods on which Sy-Quias mortgage was given had
been sold long before the execution of the mortgage in
favor of de Leon. Therefore, Sy-Quias mortgage was of
no effect.
7. The sheriff, in doubt of priority of the claims,
suspended the foreclosure proceedings and brought
the action for interpleader.
8. Sy-Quia filed for mandamus alleging that the duty of
the sheriff to proceed with the sale was merely
ministerial.
ISSUE: Whether an interpleader was proper. YES.
RATIO:
Though it, perhaps, would have 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, we, nevertheless, are of the opinion that the
facts shown do not justify our 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.
In these circumstances, his action in suspending the sale
pending the determination of the action of interpleader
seems justified.
Also, the mandamus should be directed to CFI not SC.

6 OCAMPO v. TIRONA
FACTS:
1. Ocampo alleged that he is the owner of a parcel of
land in Pasay. He bought it from Breton, the heir of the
lots registered owner (Alipio Breton).
2. Possession and administration are already in Ocampos
management even though the TCT is not yet in his
name.
3. Tirona, is a lessee occupying a portion of the subject
land from Breton-Mendiola (another heir).
4. Ocampo gave a formal written notice to Tirona about
his acquisition of the lot.
5. Tirona paid some of the monthly rentals due to
Ocampo.
6. Ocampo later received a letter from Tironas counsel
saying that Tirona is invoking her right of first refusal
since the property was declared to be under priority
development and will temporarily stop paying for the
monthly rentals.
7. Ocampo demanded for the payment of rentals and for
Tirona to vacate the premises. Tirona failed to heed
the demands.
8. Ocampo filed a complaint for unlawful detainer against
Tirona.
9. Tirona: Yanezas (allegedly the true owner) attorney in
fact recognizes Tirona as a co-owner by possession
and ceded to transfer the parcel in Tironas favor.
a. Tirona does not want to pay Ocampo because
he is not the true owner.
10.MTC: Tirona does not have any reason to suspend
payment of rents. Ocampo is entitled to use and enjoy
the property and recover it from any person unlawfully
holding it.
11.Breton-Mendiola, who claimed to be the owner of the
land, filed a motion with leave to file intervention
before the RTC.
12.RTC: Issued a writ of execution pending appeal to
enforce MTC decision. Denied intervention of BretonMendiola.
13.CA: Until the partition of the estate of Alipio is ordered
pending the partition proceedings, Ocampo cannot

rightfully claim that he bought is part of the property

occupied by Tirona.
14.Ocampo is now questioning Tironas good faith in her
preference in paying rentals to Breton-Mendiola.
ISSUE: Whether Tirona should have filed a bill of interpleader
to settle her claim. YES.
RATIO:
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.
Ocampo has the right to eject Tirona. There was unlawful
detainer.

7 PAGKALINAWAN v. RODAS, GARCIA, TAMBUNTING

FACTS:
1. In an ejectment suit between Tambunting and Alfonso
and Miguel Pagkalinawan, the Pagkalinawans were
ordered to vacate the house and pay Tambunting the
rentals at the rate of P45 a month.
2. Acting upon a motion for reconsideration by the
Pagkalinawans, CFI set aside the order and absolved
the Pagkalinawans from the complaint.
3. Tambunting moved for reconsideration, as a result, the
CFI ordered the issuance of a writ of execution. The
Pagkalinawans were ordered to pay the rentals directly
to Tambunting.
4. The Pagkalinawans sought to stay the execution on the
ground that they had, in the meantime, filed with the
same court an interpleader suit against Tambunting
and Ong, praying for them to litigate regarding their
conflicting claims to the rentals due from the
Pagkalinawans.
a. This is because the Pagkalinawans received a
notice from Ong advising them to stop paying
the rentals to Tambunting.
5. CFI: Directed that execution be proceeded with.
6. The Pagkalinawans filed for certiorari, prohibition
seeking the desistance of carrying out the writ of
execution.
ISSUE: Whether the interpleader suit was proper considering
that a writ of execution had already been issued. YES.
RATIO:
It appears in the interpleader suit filed by the
Pagkalinawans, said rentals were deposited with the clerk
of court.
Such deposit constituted a bona fide compliance with the
decision of the judge, since it is undeniable that the
Pagkalinawans were warned by Ong not to pay the rentals
to Tambunting.
Under the law, the Pagkalinawans have a right to file the
interpleader suit because of the claims for rentals of Ong.

And if Tambunting believes that he is legally entitled to

said rentals, he is free to move for the withdrawal of the
deposits made by the Pagkalinawans.
Judge and sheriff ordered to desist from carrying out the
writ of execution issued.

8 MESINA v. IAC, GO and UY

FACTS:
1. Go purchased from Associated Bank a Cashiers Check
for P800k.
a. He left said check on top of the desk of the bank
manager when he left the bank.
2. The manager entrusted the check for safekeeping to
Uy, a bank official.
a. Uy was having a visitor (Lim) when the check
was entrusted.
b. Uy stepped out and when he came back, Lim
was already gone.
3. Go inquired about the check but it could not be found
on Uys folder or anywhere else.
4. Uy advised Go to accomplish a STOP PAYMENT order,
which Go immediately followed. He also executed an
affidavit of loss.
5. Uy went to the police to report the loss pointing to the
person of Lim as the one who could explain the
incident.
6. It was discovered that Associated Bank received the
check for clearing from Prudential Bank but Associated
immediately dishonored it and stopped payment.
7. Several days later, a certain Atty. Navarro demanded
payment on the cashiers check for his client. He
threatened to sue if demand is not heeded. Associated
Bank told him that the check belonged to Go.
8. Associated Bank filed an action for Interpleader
naming Go and John Doe (Navarros client) as
respondents.
9. Associated Bank received the complaint for damages
from Mesina, prompting it to amend its complaint.
10.When Mesina was asked, he said that the check was
paid to him by Lim in a certain transaction.
11.An information for theft was instituted against Lim,
warrant issued but remains unserved because of Lims
successful evasion.
12.Go moved to participate as intervenor in the complaint
for damages.
13.Uy moved for intervention in the complaint for
interpleader.

14.Mesina instead of filing an Answer, he filed an omnibus

motion to dismiss for lack of jurisdiction, failire to state
cause of action, lack of personality to sue.
15.Asociated Bank moved to dismiss the other civil case
for damages in view of the Interpleader case.
16.TC, Interpleader Case: Associated Bank has cause of
action for interpleader.
a. Mesina was declared in default for not filing
Answer and set the presentation of Associated
Banks evidence.
17.Mesina filed a Pet. for Certiorari with IAC. Dismissed.
18.TC, Interpleader: Associate Bank shall replace the
Cashiers Check in favor of Go.
19.TC, Damages: Moot and academic. Already resolved in
favor of Go in the Interpleader suit.
20.Mesina appealed. He said the interpleader was not
proper and showed no conflicting claims. He shouldnt
be declared in default because there was no order for
him to plead in the interpleader case.
ISSUE: Whether the interpleader suit by the Bank was proper
even if there was already a claim for damages against it in a
separate case. YES.
RATIO:
Associated Bank merely took the necessary precaution
not to make a mistake as to whom to pay the amount.
Go and Mesina were both claiming based on the check.
Mesina argued that the interpleader relieved the Bank
from liability is wrong.
o Bank is willing to make a time deposit of P800k to
the clerk of court and award it to whoever will be
found entitled to it.
Bank filed the interpleader suit not because Mesina sued
it but because Mesina is laying claim to the same check
that Go is claiming.
When Bank instituted the interpleader, it was not aware of
any suit for damages filed against it. It was first addressed
to a John Doe.

An order to the parties named in a petition for

interpleader to file answer is an order to interplead. Nonanswering party liable to be declared in default.

9 VDA. DE CAMILO ET. AL v. JUSTICE ARCAMO, KEE, and

ONG

ISSUE: Whether the Justice of the Peace Court has

jurisdiction to take cognizance of the Interpleader case. NO.

FACTS:
1. Petra Carpio vda. de Camilo had been in peaceful,
open, and adverse possession of a parcel of public
foreshore land in Zamboanga.
2. A commercial building was erected on the property.
3. Kee was a lessee of one of the apartments of said
commercial building.
4. Bannister filed an unlawful detainer case against de
Camilo and Kee.
5. The other petitioners, all surnamed Francisco, had also
been in possession of a parcel of public land adjoining
the land occupied by de Camilo. They erected a
commercial building therein.
6. The two commercial buildings were burned down.
7. 2 weeks after, Kee and Ong constructed a building of
their own. This was built in a portion previously
occupied by de Camilo and Francisco.
8. De Camilo filed a case for Forcible Entry against Kee
and Ong for the portion of her property encroached
upon before the Justice of Peace. The Franciscos filed a
similar case.
9. Ong/Kee: The land was leased to them by the
Municipality of Malangas.
10.Pending trial of the two cases, Ong and Kee filed a
complaint for Interpleader against de Camilo, Estrada,
Franciscos, Bannister, Mayor and Treasurer of
Malangas alleging that the filing of the cases for
forcible entry indicated that the defendants had
conflicting interest since they all claimed to be entitled
to the possession of the lot in question.
11.Ong and Kee alleged that they do not have interest on
the property other than as mere lessees.
12.De Camilo et. al instituted certiorari and mandamus
claiming that the Justice abused his discretion for
giving due course to the interpleader and it lacked
cause of action.
13.CFI: Justice had no jurisdiction to try the interpleader.

RATIO:
De Camilo et. al did not have conflicting claims against
Ong and Kee.
Their respective claim was separate and distinct from the
other.
o De Camilo wanted Ong and Kee to vacate the
portion of her property encroached upon by them.
o Same with Estrada and Franciscos.
They claimed possession of two different parcels of land,
of different areas, adjoining each other.
Ong and Kee HAVE interest in the subject matter. Their
interest was the prolongation of their occupancy of the
portions they encroached upon.
The requirements for a complaint of interpleader do NOT
exist.
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
Ong and Kee.

10 BELTRAN v. PEOPLES HOMESITE AND HOUSING

CORP.
FACTS:
1. Beltran et. al were occupying housing units at Proj. 4 in
QC under lease from PHHC.
2. They were assured by competent authority that after 5
years of continuous occupancy, they would be entitled
to purchase the units.
3. PHHC then announced that the management,
administration and ownership of Proj. 4 would be
transferred to GSIS because of PHHCs debt to it.
4. PHHC asked the tenants to signify their conformity to
buy the units, agreeing to credit to the tenants as
down payment the 30% they already paid as rentals.
Tenants accepted.
5. PHHC announced that all payments made by the
tenants after the date indicated shall be considered as
amortizations or installment-payments.
6. All collections were delivered to GSIS.
7. After the turnover to GSIS, PHHCs new manager
refused to recognize all agreements and undertakings
previously entered into with GSIS. GSIS insisted to
enforce the said agreements and was upheld by the
Government Corporate Counsel and the Secretary of
Justice.
8. Beltran et. al filed for an interpleader against PHHC
and GSIS claiming that they did not know to whom
they should pay the monthly amortization.
9. TC: Designated Peoples First Savings Bank to receive
in trust the payments from Beltran et al and to be
released only upon proper authority of the Court.
10.PHHC and GSIS filed a motion to dismiss for failure to
state cause of action.
11.TC: Dismissed the complaint. GSIS had no objection
that payments on the monthly amortizations be made
directly to PHHC.
12.During the conference, PHHC and GSIS managers
assured the counsel of Beltran et al that upon payment
of the whole purchase price, the title will be issued.

13.Beltran et al appealed saying that they still do not

know who between GSIS and PHHC is the right and
lawful party to receive their amortizations.
ISSUE: Whether an action for interpleader was proper. NO.
RATIO:
Beltran et al missed the vital element of an action of
interpleader.
o The Rules require 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 is not
disputed by the claimants.
o While PHHC and GSIS have conflicting claims
between
themselves
with
regard
to
the
management, ownership, and administration of
Project 4, such claims are not against Beltran et al
nor do they involve or affect Beltran et al.
o The question of fact raised in their complaint
concerning the enforceability, and recognition or
non-enforceability and non-recognition of the
turnover agreement between PHHC and GSIS are
irrelevant to their action of interpleader, for these
conflicting claims are between the two corporations
and not against plaintiffs. PHHC and GSIS 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.
The resolution of the issue of breach of the defendants'
undertakings towards plaintiffs may not properly be
sought through the special civil action of interpleader.
Plaintiffs' recourse would be an ordinary action of specific
performance or other appropriate suit against the
defendants or either of them as the circumstances
warrant.