ARREZA v DIAZ

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

Balara Quezon City. It instituted an interpleader case against Arreza and Diaz who were
conflicting claimants of the property. the RTC ruled in favor of Arreza. In view of said
decision, Bliss executed a contract to sell the property 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 reimbursement of the cost of the
improvements which amounted to approximately 1.7 M inclusive of 8% interest. Arreza
filed a Motion to Dismiss on the ground of res judicata and lack of cause of action. RTC
dismissed the Motion to Dismiss and the Motion for Reconsideration of Arreza. This
prompted Arreza to file a petition for certiorari with the CA. CA dismissed the petition
saying that res judicata does not apply because the interpleader case only settled the
issue on who had a better right. It did not determine the parties respective rights and
obligations.
ISSUE: Whether or not the claim for reimbursement is barred by res judicata YES
HELD: An examination of the answer filed by Diaz showed that he asserted his status as
a buyer in good faith and for value and he prayed that affirmative relief arising out of
the rights of a buyer in good faith and for value be granted. This only means that Diaz
expected that the court shall award him damages in the form of reimbursement in case
judgment is rendered in favor of Arreza. Diaz contends that in the pre-trial of the
interpleader case, reimbursement and damages was never put in issue. Thus it could
not have been the subject of the interpleader and consequently, not barred by res
judicata. Diaz says it was incumbent on Arreza to include the damages as an issue. The
Supreme Court said that (1) it is not the duty of the petitioner to do the lawyering
against the respondent and (2) in a complaint for interpleader shall determine the
rights and obligations of the parties and adjudicate their respective claims. Such rights,
obligations, and claims could only be adjudicated if put forward by the aggrieved party
in assertion of his rights. That party in this case referred to respondent Diaz. The
second paragraph of Section 5 of Rule 62 of the 1997 Rules of Civil Procedure provides
that the parties in an interpleader action may file counterclaims, cross-claims, third
party complaints and responsive pleadings thereto, "as provided by these Rules." The
second paragraph was added to Section 5 to expressly authorize the additional
pleadings and claims enumerated therein, in the interest of a complete adjudication of
the controversy and its incidents. Having failed to set up his claim for reimbursement,
said claim of respondent Diaz being in the nature of a compulsory counterclaim is now
barred.

Almeda v Bathala Marketing

Facts: Bathala Marketing leased the property belonging to Almeda. It was a 4-year lease
contract which started on May 1, 1997. The parties stipulated that the present rental
price was based on the present rate of assessment, and that in the event that any new
tax or burden was imposed by authorities, the rental price will be increased to reflect
such new tax or burden (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 provision
which provided that in the event of extraordinary inflation or deflation, the value of the
peso at the time of the establishment of the contract was to be followed. Come
December 1997, Almeda advised Bathala that VAT will now be applied to the rentals.
Bathala contended that since VAT was already in effect when the contract was entered
into, then no increase should be done. In January 1998, Almeda told Bathala that the
rent was to be increased by 73% because of inflation. Bathala rejected the claim,
saying that only the court can pronounce extraordinary inflation. Bathala instituted an
action for declaratory relief. After, Almeda filed an ejectment case against Bathala.
Almeda also moved for the dismissal of the declaratory relief because it claimed that
Bathala was already in breach of its obligation. The RTC and CA ruled for Bathala.
Issue: Was the action for declaratory relief proper?
Held: Yes, it certainly was. Declaratory relief is defined as an action by any person
interested in a deed, will, contract or other written instrument, executive order or
resolution, to determine any question of construction or validity arising from the
instrument, executive order or regulation, or statute, and for a declaration of his rights
and duties thereunder. The only issue that may be raised in such a petition is the
question of construction or validity of provisions in an instrument or statute. Corollary is
the general rule that such an action must be justified, as no other adequate relief or
remedy is available under the circumstances. [ The requisites are: 1) the subject matter
of the controversy must be a deed, will, contract or other written instrument, statute,
executive order or regulation, or ordinance; 2) the terms of said documents and the
validity thereof are doubtful and require judicial construction; 3) there must have been
no breach of the documents in question; 4) there must be an actual justiciable
controversy or the ripening of one between per persons whose interests are adverse; 5)
the issue must be ripe for judicial determination; and 6) adequate relief is not available
through other means or other forms of action or proceeding. After Almeda demanded
payment of adjusted rentals and in the months that followed, Bathala complied with the
terms and conditions set forth in their contract of lease by paying the rentals stipulated
therein. Bathala religiously fulfilled its obligations to petitioners even during the
pendency of the present suit. Bathala did not breach the contract. Thus, Bathala is not
barred from instituting the petition for declaratory relief. Issue: Is declaratory relief
proper given that there is already a separate action for ejectment, and thus the issues
should be ventilated there? In Panganiban v. Pilipinas Shell Petroleum Corporation, the
SC held that the petition for declaratory relief should be dismissed in view of the
pendency of a separate action for unlawful detainer. However, in that case, the
unlawful detainer case had already been resolved by the trial court before the dismissal
of the declaratory relief case. Here, the trial court had not yet resolved the
rescission/ejectment case during the pendency of the declaratory relief petition. In 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 declaratory relief. There was
a case where the declaratory relief action was dismissed because the issue therein
could be threshed out in the unlawful detainer suit (Teodoro v Mirasol). But in that case,
there was already a breach of contract at the time of the filing of the declaratory relief
petition. Thus, it is proper to entertain the instant declaratory relief action, even with
the pendency of the ejectment/rescission case before the trial court. The resolution of

the present petition would write finis to the dispute, as it would settle once and for all
the question of the proper interpretation of the two contractual stipulations subject of
this controversy.

RCBC v. Metro Container Corp.

FACTS: Sept. 1990, Ley Construction Corporation (LEYCON) contracted a loan from
RCBC in the amount of P30 million which was secured by a real estate mortgage over a
Valenzuela property. LEYCON failed to settle its obligations prompting RCBC to institute
extrajudicial foreclosure proceedings against it and in Dec. 1992, RCBC was the highest
bidder.
LEYCON as a response, filed an action for Nullificatoin of Extrajudicial Foreclosure Sale
and Damages against RCBC but eventually RCBC was able to consolidate its ownership
over the property due to LEYCONs failure to redeem. Metro Container Corporation
(METROCAN) which was leasing the property from LEYCON was demanded by RCBC to
make rental payments. LEYCON filed an action for Unlawful Detainer against
METROCAN.
METROCAN, meanwhile, filed a complaint for Interpleader against LEYCON and RCBC to
compel them to interplead and litigate their several claims among themselves and to
determine which among them shall rightfully receive the payment of monthly rentals.
In the Interpleader case, an amicable settlement was made between METROCAN and
LEYCON with respect to back rentals. However, in the Unlawful Detainer case,
METROCAN was order to pay LEYCON whatever rentals were due. METRPCAN claims
interpleader case is moot and academic because of amicable settlement. RCBC alleges,
however, that the decision of the lower court in the ejectment case cannot render the
Interpleader action moot and academic.
ISSUE: W/N the Party who initiates the interpleader action may be compelled to litigate
if he is no longer interested to pursue such cause of action?
RULING: It is undisputed that METROCAN filed the interpleader action because LEYCON
was claiming payment of the rentals as lessor and RCBC was making a demand by
virtue of the consolidation of the title of the property in its name. The Supreme Court
said that the unlawful detainer case involves issue of material possession and not of
ownership, therefore, the reason for the interpleader ceased when the lower court
rendered judgment ordering METROCAN to pay LEYCON. It should be remembered that
an action for interpleader is afforded to protect a person not against double liability but
against double vexation in respect of one liability.

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). Provisions of the contract of lease include:
6th - Lessee shall pay an increased rent if there is any new tax imposed on the property
7th - In case of supervening extraordinary inflation or devaluation of the PHP, the value of PHP at
the time of the establishment of the obligation shall be the basis of payment
Petitioners later demanded payment of VAT and 73% adjusted rentals pursuant to the foregoing
provisions. Respondent refused and filed an action for declaratory relief. Petitioners filed an action
for ejectment.
Issue: Whether or not declaratory relief is proper.
Held: YES. Petitioners insist that respondent was already in breach of the contract when the petition
was filed, thus, respondent is barred from filing an action for declaratory relief. However, after
petitioners demanded payment of adjusted rentals and in the months that followed, respondent
complied with the terms and conditions set forth in their contract of lease by paying the rentals
stipulated therein. Respondent religiously fulfilled its obligations to petitioners even during the
pendency of the present suit. There is no showing that respondent committed an act constituting a
breach of the subject contract of lease. Thus, respondent is not barred from instituting before the
trial court the petition for declaratory relief.
Petitioners further claim that the instant petition is not proper because a separate action for
rescission, ejectment and damages had been commenced before another court; thus, the
construction of the subject contractual provisions should be ventilated in the same forum.
As a rule, the petition for declaratory relief should be dismissed in view of the pendency of a
separate action for unlawful detainer. In this case, however, the trial court had not yet resolved the
rescission/ejectment 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.

CLASSIFICATION OF CRIMES AS TO GRAVITY

I. The basis is the penalty prescribed by the RPC and not the actual penalty imposed by the court. If both
imprisonment and fine are prescribed as penalties, it is the penalty of imprisonment which is used as basis.

II. The classifications are:

A. Light- the penalty is imprisonment of one day to thirty days or fine of not more than P200.00
1. They are punished only in their consumated stages except with respect to light felonies against
persons or property. The reason is because they produced such light or insignificant results that society
is satisfied if they are punished even if only in their consummated stage.
2. Only principals and accessories are liable

B Less Grave: by imprisonment of more than one month but not more than 6 years or fine of P200.00 but
not more than P6,000.00

C. Grave: the imprisonment is more than 6 years or fine of more than P6,000.00. They are either 1.
Heinous- the penalty is reclusion temporal to reclusion perpetua or 2. Non heinous.

II. The Importance of the classification is in relation to (a) prescription of crimes (b) complexing of crimes (c)
imposition of subsidiary penalty (d) determination of who are liable for the offense (e) determination what
stage of execution is punishable and (f) determination of the period of detention of persons lawfully arrested
without warrant.