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Interpleader Digest

This document discusses two cases involving interpleader actions. In the first case, Wack Wack Golf & Country Club filed an interpleader action after a final judgment had been rendered against it in a previous case, which was found to be too late. In the second case, Eternal Gardens Memorial Parks Corporation filed an interpleader action and was ordered to deposit amounts owed and in dispute with the court, which was found to be proper given the nature of interpleader actions.

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40 views

Interpleader Digest

This document discusses two cases involving interpleader actions. In the first case, Wack Wack Golf & Country Club filed an interpleader action after a final judgment had been rendered against it in a previous case, which was found to be too late. In the second case, Eternal Gardens Memorial Parks Corporation filed an interpleader action and was ordered to deposit amounts owed and in dispute with the court, which was found to be proper given the nature of interpleader actions.

Uploaded by

Nis Sa
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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WACK WACK GOLF & COUNTRY CLUB, INC.

, plaintiff-appellant,
vs.
LEE E. WON alias RAMON LEE and BIENVENIDO A. TAN, defendants-appellees
FACTS:

Wack Wack Golf & Country Club, Inc. alleged, for its first cause of action, that the defendant
Lee E. Won claims ownership of its membership fee certificate 201. Defendant Bienvenido A.
Tan, on the other hand, claims to be lawful owner of its aforesaid membership fee certificate
201 by virtue of membership fee certificate 201. For its second cause of action. it alleged that
the membership fee certificate 201-serial no. 1478 issued by the deputy clerk of court of court
of the CFI of Manila in behalf of the Corporation is null and void because issued in violation of
its by-laws,

ISSUE:

WON the remedy of interpleader is proper and timely? NO

RULING:

A stakeholder 6 should use reasonable diligence to hale the contending claimants to court. 7 He


need not await actual institution of independent suits against him before filing a bill of
interpleader. 8 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. 9 Otherwise, he
may be barred by laches 10 or undue delay. 11 But where he acts with reasonable diligence in
view of the environmental circumstances, the remedy is not barred.

It was aware of the conflicting claims of the appellees with respect to the membership fee
certificate 201 long before it filed the present interpleader suit. It had been recognizing Tan as
the lawful owner thereof. It was sued by Lee who also claimed the same membership fee
certificate. Yet it did not interplead Tan. It preferred to proceed with the litigation (civil case
26044) and to defend itself therein. As a matter of fact, final judgment was rendered against it
and said judgment has already been executed. It is not therefore too late for it to invoke the
remedy of interpleader.

It has been held that a stakeholder's action of interpleader is too late when filed after judgment
has been rendered against him in favor of one of the contending claimants, 13 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.

The Corporation has not shown any justifiable reason why it did not file an application for
interpleader in civil case 26044 to compel the appellees herein to litigate between themselves
their conflicting claims of ownership. It was only after adverse final judgment was rendered
against it that the remedy of interpleader was invoked by it. By then it was too late, because to
he entitled to this remedy the applicant must be able to show that lie has not been made
independently liable to any of the claimants. And since the Corporation is already liable to Lee
under a final judgment, the present interpleader suit is clearly improper and unavailing.
To now permit the Corporation to bring Lee to court after the latter's successful establishment
of his rights in civil case 26044 to the membership fee certificate 201, is to increase instead of
to diminish the number of suits, which is one of the purposes of an action of interpleader, with
the possibility that the latter would lose the benefits of the favorable judgment. This cannot be
done because having elected to take its chances of success in said civil case 26044, with full
knowledge of all the fact, the Corporation must submit to the consequences of defeat.

ETERNAL GARDENS MEMORIAL PARKS CORPORATION, petitioner,


vs.
FIRST SPECIAL CASES DIVISION INTERMEDIATE APPELLATE COURT and
NORTH PHILIPPINE UNION MISSION OF THE SEVENTH-DAY
ADVENTISTS, respondents.

FACTS:
Petitioner Eternal Gardens Memorial Parks Corporation and private respondent North
Philippine Union Mission Corporation of the Seventh Day Adventists (MISSION for
short). They executed a Land Development Agreement whereby the former undertook
to introduce and construct at its own expense and responsibility necessary
improvements on the property owned by private respondent. Out of the proceeds from
the sale, private respondent is entitled to receive 40% of the net gross collection from
the project to be remitted monthly by petitioner to private respondent through a
designated depositary trustee bank.
All went well until Maysilo Estate asserted its claim of ownership over the parcel of land
in question. Confronted with such conflicting claims, petitioner as plaintiff filed a
complaint for interpleader (Rollo, pp. 169-179) against private respondent MISSION and
Maysilo Estate alleging that in view of the conflicting claims of ownership of the
defendants over the properties subject matter of the contracts, over which plaintiff
corporation (herein petitioner) has no claim of ownership except as a purchaser thereof,
and to protect the interests of plaintiff corporation which has no interest in the subject
matter of the dispute and is willing to pay whoever is entitled or declared to be the
owners.
Private respondent presented a motion for the placing on judicial deposit the amounts
due and unpaid from petitioner. Acting on such motion, the trial court 3 denied judicial
deposit.
ISSUE:
WON the judicial deposit is proper in the complaint for interpleader? YES
RULING:
a careful analysis of the records will show that petitioner admitted among others in its
complaint in Interpleader that it is still obligated to pay certain amounts to private
respondent; that it claims no interest in such amounts due and is willing to pay whoever
is declared entitled to said amounts. Such admissions in the complaint were reaffirmed
in open court before the Court of Appeals.

Under the circumstances, there appears to be no plausible reason for petitioner's


objections to the deposit of the amounts in litigation after having asked for the
assistance of the lower court by filing a complaint for interpleader where the deposit of
aforesaid amounts is not only required by the nature of the action but is a contractual
obligation of the petitioner under the Land Development Program (Rollo, p. 252).

As correctly observed by the Court of Appeals, the essence of an interpleader, aside


from the disavowal of interest in the property in litigation on the part of the petitioner,
is the deposit of the property or funds in controversy with the court. it is a rule founded
on justice and equity: "that the plaintiff may not continue to benefit from the property
or funds in litigation during the pendency of the suit at the expense of whoever will
ultimately be decided as entitled thereto."

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