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ARREZA v DIAZ

FACTS: Bliss Development Corporation is the owner of a housing complex located in

Balara Quezon Cit! "t instituted an interpleader case against Arreza and Diaz who were

con#icting claimants of the propert! the $TC ruled in favor of Arreza! "n view of said

decision% Bliss executed a contract to sell the propert to Arreza and Diaz was

compelled to transfer possession together with all improvements to Arreza! Thereafter%

Diaz instituted a claim against Arreza and Bliss for the reim&ursement of the cost of theimprovements which amounted to approximatel '!( ) inclusive of *+ interest! Arreza

,led a )otion to Dismiss on the ground of res -udicata and lac. of cause of action! $TC

dismissed the )otion to Dismiss and the )otion for $econsideration of Arreza! This

prompted Arreza to ,le a petition for certiorari with the CA! CA dismissed the petition

saing that res -udicata does not appl &ecause the interpleader case onl settled the

issue on who had a &etter right! "t did not determine the parties/ respective rights and

o&ligations!

"SS01: 2hether or not the claim for reim&ursement is &arred & res -udicata 3 41S

516D: An examination of the answer ,led & Diaz showed that he asserted his status as

a &uer in good faith and for value and he praed that a7rmative relief arising out of

the rights of a &uer in good faith and for value &e granted! This onl means that Diaz

expected that the court shall award him damages in the form of reim&ursement in case

 -udgment is rendered in favor of Arreza! Diaz contends that in the pre8trial of the

interpleader case% reim&ursement and damages was never put in issue! Thus it could

not have &een the su&-ect of the interpleader and conse9uentl% not &arred & res

 -udicata! Diaz sas it was incum&ent on Arreza to include the damages as an issue! The

Supreme Court said that '; it is not the dut of the petitioner to do the lawering

against the respondent and <; in a complaint for interpleader shall determine the

rights and o&ligations of the parties and ad-udicate their respective claims! Such rights%

o&ligations% and claims could onl &e ad-udicated if put forward & the aggrieved part

in assertion of his rights! That part in this case referred to respondent Diaz! The

second paragraph of Section = of $ule >< of the '??( $ules of Civil @rocedure provides

that the parties in an interpleader action ma ,le counterclaims% cross8claims% third

part complaints and responsive pleadings thereto% as provided & these $ules! The

second paragraph was added to Section = to expressl authorize the additional

pleadings and claims enumerated therein% in the interest of a complete ad-udication of

the controvers and its incidents! 5aving failed to set up his claim for reim&ursement%

said claim of respondent Diaz &eing in the nature of a compulsor counterclaim is now

&arred!

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Almeda v Bathala Marketing

Facts: Bathala )ar.eting leased the propert &elonging to Almeda! "t was a 8ear lease

contract which started on )a '% '??(! The parties stipulated that the present rental

price was &ased on the present rate of assessment% and that in the event that an new

tax or &urden was imposed & authorities% the rental price will &e increased to re#ect

such new tax or &urden there was also a provision which provided for the decrease of

the rental price in the event that the taxes were lowered;! There was another provisionwhich provided that in the event of extraordinar in#ation or de#ation% the value of the

peso at the time of the esta&lishment of the contract was to &e followed! Come

Decem&er '??(% Almeda advised Bathala that AT will now &e applied to the rentals!

Bathala contended that since AT was alread in eect when the contract was entered

into% then no increase should &e done! "n Eanuar '??*% Almeda told Bathala that the

rent was to &e increased & (+ &ecause of in#ation! Bathala re-ected the claim%

saing that onl the court can pronounce extraordinar in#ation! Bathala instituted an

action for declarator relief! After% Almeda ,led an e-ectment case against Bathala!

Almeda also moved for the dismissal of the declarator relief &ecause it claimed that

Bathala was alread in &reach of its o&ligation! The $TC and CA ruled for Bathala!

"ssue: 2as the action for declarator relief properG

5eld: 4es% it certainl was! Declarator relief is de,ned as an action & an person

interested in a deed% will% contract or other written instrument% executive order or

resolution% to determine an 9uestion of construction or validit arising from the

instrument% executive order or regulation% or statute% and for a declaration of his rights

and duties thereunder! The onl issue that ma &e raised in such a petition is the

9uestion of construction or validit of provisions in an instrument or statute! Corollar is

the general rule that such an action must &e -usti,ed% as no other ade9uate relief or

remed is availa&le under the circumstances! H The re9uisites are: '; the su&-ect matter

of the controvers must &e a deed% will% contract or other written instrument% statute%

executive order or regulation% or ordinanceI <; the terms of said documents and the

validit thereof are dou&tful and re9uire -udicial constructionI ; there must have &een

no &reach of the documents in 9uestionI ; there must &e an actual -usticia&le

controvers or the ripening of one &etween per persons whose interests are adverseI =;

the issue must &e ripe for -udicial determinationI and >; ade9uate relief is not availa&le

through other means or other forms of action or proceeding! After Almeda demanded

pament of ad-usted rentals and in the months that followed% Bathala complied with the

terms and conditions set forth in their contract of lease & paing the rentals stipulated

therein! Bathala religiousl ful,lled its o&ligations to petitioners even during the

pendenc of the present suit! Bathala did not &reach the contract! Thus% Bathala is not

&arred from instituting the petition for declarator relief! "ssue: "s declarator reliefproper given that there is alread a separate action for e-ectment% and thus the issues

should &e ventilated thereG "n @angani&an v! @ilipinas Shell @etroleum Corporation% the

SC held that the petition for declarator relief should &e dismissed in view of the

pendenc of a separate action for unlawful detainer! 5owever% in that case% the

unlawful detainer case had alread &een resolved & the trial court &efore the dismissal

of the declarator relief case! 5ere% the trial court had not et resolved the

rescissionJe-ectment case during the pendenc of the declarator relief petition! "n fact%

the trial court% where the rescission case was on appeal% itself initiated the suspension

of the proceedings pending the resolution of the action for declarator relief! There was

a case where the declarator relief action was dismissed &ecause the issue therein

could &e threshed out in the unlawful detainer suit Teodoro v )irasol;! But in that case%there was alread a &reach of contract at the time of the ,ling of the declarator relief

petition! Thus% it is proper to entertain the instant declarator relief action% even with

the pendenc of the e-ectmentJrescission case &efore the trial court! The resolution of

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the present petition would write ,nis to the dispute% as it would settle once and for all

the 9uestion of the proper interpretation of the two contractual stipulations su&-ect of

this controvers!

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RCBC v. Metro Container Corp.

FACTS: Sept! '??K% 6e Construction Corporation 614CLM; contracted a loan from$CBC in the amount of @K million which was secured & a real estate mortgage over aalenzuela propert! 614CLM failed to settle its o&ligations prompting $CBC to instituteextra-udicial foreclosure proceedings against it and in Dec! '??<% $CBC was the highest&idder!

614CLM as a response% ,led an action for Mulli,catoin of 1xtra-udicial Foreclosure Saleand Damages against $CBC &ut eventuall $CBC was a&le to consolidate its ownershipover the propert due to 614CLMNs failure to redeem! )etro Container Corporation)1T$LCAM; which was leasing the propert from 614CLM was demanded & $CBC toma.e rental paments! 614CLM ,led an action for 0nlawful Detainer against)1T$LCAM!

)1T$LCAM% meanwhile% ,led a complaint for "nterpleader against 614CLM and $CBC tocompel them to interplead and litigate their several claims among themselves and todetermine which among them shall rightfull receive the pament of monthl rentals!"n the "nterpleader case% an amica&le settlement was made &etween )1T$LCAM and

614CLM with respect to &ac. rentals! 5owever% in the 0nlawful Detainer case%)1T$LCAM was order to pa 614CLM whatever rentals were due! )1T$@CAM claimsinterpleader case is moot and academic &ecause of amica&le settlement! $CBC alleges%however% that the decision of the lower court in the e-ectment case cannot render the"nterpleader action moot and academic!

ISSUE: 2JM the @art who initiates the interpleader action ma &e compelled to litigateif he is no longer interested to pursue such cause of actionG

RULI!: "t is undisputed that )1T$LCAM ,led the interpleader action &ecause 614CLMwas claiming pament of the rentals as lessor and $CBC was ma.ing a demand &

virtue of the consolidation of the title of the propert in its name! The Supreme Courtsaid that the unlawful detainer case involves issue of material possession and not ofownership% therefore% the reason for the interpleader ceased when the lower courtrendered -udgment ordering )1T$LCAM to pa 614CLM! "t should &e remem&ered thatan action for interpleader is aorded to protect a person not against dou&le lia&ilit &utagainst dou&le vexation in respect of one lia&ilit!

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Almeda vs. Bathala Marketing Industries,Inc.

Facts: In May 1997, respondent Bathala Marketing Industries, Inc. (lessee) entered into a contract

of lease with petitioners (lessors). Proisions of the contract of lease include!

"th # $essee shall pay an increased rent if there is any new ta% i&posed on the property

7th # In case of superening e%traordinary inflation or dealuation of the P'P, the alue of P'P at

the ti&e of the estalish&ent of the oligation shall e the asis of pay&ent

Petitioners later de&anded pay&ent of *+ and 7- adusted rentals pursuant to the foregoing

proisions. /espondent refused and filed an action for declaratory relief. Petitioners filed an action

for eect&ent.

Issue: 0hether or not declaratory relief is proper.

Held: 23. Petitioners insist that respondent was already in reach of the contract when the petition

was filed, thus, respondent is arred fro& filing an action for declaratory relief. 'oweer, after 

petitioners de&anded pay&ent of adusted rentals and in the &onths that followed, respondent

co&plied with the ter&s and conditions set forth in their contract of lease y paying the rentals

stipulated therein. /espondent religiously fulfilled its oligations to petitioners een during the

pendency of the present suit. +here is no showing that respondent co&&itted an act constituting a

reach of the suect contract of lease. +hus, respondent is not arred fro& instituting efore the

trial court the petition for declaratory relief.

Petitioners further clai& that the instant petition is not proper ecause a separate action for 

rescission, eect&ent and da&ages had een co&&enced efore another court4 thus, the

construction of the suect contractual proisions should e entilated in the sa&e foru&.

 *s a rule, the petition for declaratory relief should e dis&issed in iew of the pendency of a

separate action for unlawful detainer. In this case, howeer, the trial court had not yet resoled the

rescission5eect&ent case during the pendency of the declaratory relief petition. In fact, the trial

court, where the rescission case was on appeal, initiated the suspension of the proceedings

pending the resolution of the action for declaratory relief.

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CLASSIFICATIO OF C!IM"S AS TO #!A$IT%

 

I. +he asis is the penalty prescried y the /P6 and not the actual penalty i&posed y the court. If oth

i&prison&ent and fine are prescried as penalties, it is the penalty of i&prison&ent which is used as asis.

 

II. +he classifications are!

 *. $ight# the penalty is i&prison&ent of one day to thirty days or fine of not &ore than P88.88

1. +hey are punished only in their consu&ated stages e%cept with respect to light felonies against

persons or property. +he reason is ecause they produced such light or insignificant results that society

is satisfied if they are punished een if only in their consu&&ated stage.

. nly principals and accessories are liale

 

B $ess :rae! y i&prison&ent of &ore than one &onth ut not &ore than " years or fine of P88.88 ut

not &ore than P",888.88

 

6. :rae! the i&prison&ent is &ore than " years or fine of &ore than P",888.88. +hey are either 1.

'einous# the penalty is reclusion te&poral to reclusion perpetua or . ;on heinous.

 

II. +he I&portance of the classification is in relation to (a) prescription of cri&es () co&ple%ing of cri&es (c)i&position of susidiary penalty (d) deter&ination of who are liale for the offense (e) deter&ination what

stage of e%ecution is punishale and (f) deter&ination of the period of detention of persons lawfully arrested

without warrant.