Digest Author: F.
Atienza
ARREZA v DIAZ (2001)
Petitioner: EDGAR ARREZA,
Respondent: MONTANO DIAZ
DOCTRINE: 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
FACTS:
1. Bliss Development Corp is the owner of a housing unit in New Capitol
Estates, QC. In the course of a case involving conflict of ownership
between Arreza and Diaz, Bliss Devt. Filed a complaint for interpleader
before the RTC.
2. RTC ruled in favor of Arreza. Decision became final and was executed
with Bliss executing a contract to sell of the said land to Arreza.
3. Thereafter, Diaz filed a complaint against Bliss and Arreza for
reimbursement of more than 1 million pesos for the cost of acquisition and
improvements over the property.
4. Arreza filed an MTD citing res adjudicate or conclusiveness of judgment in
the interpleader case as well as lack of cause of action.
5. MTD was denied. Certiorari was filed by Arreza before the CA. CA
dismissed the PetCert. It ruled that:
a. The decision invoked by the petitioner as res adjudicata resolved
only the issue of who between Edgar H. Arreza and Montano Diaz
has the better right over the property under litigation. It did not
resolve the rights and obligations of the parties.
b. The action filed by Montano M. Diaz against Bliss Development
Corporation, et al. seeks principally the collection of damages in
the form of the payments Diaz made to the defendant and the
value of the improvements he introduced on the property matters
that were not adjudicated upon in the previous case for
interpleader.
ISSUES:
1. Whether or not Res Adjudicata is present in this case. - Y
RULING + RATIO:
1. Yes.
The elements of res adjudicata are: (a) that the former judgment
must be final; (b) the court which rendered judgment had
jurisdiction over the parties and the subject matter; (c) it must be
a judgment on the merits; and (d) there must be between the first
and second causes of action identity of parties, subject matter,
and cause of action.
Prior case of interpleader was settled with finality and judgment
therein is now final.
Jurisdiction over the parties and subject matter was present in the
first case even if property was in QC but the action was filed in
Makati because:
i. By asserting his right as a buyer for value and in good
faith of the subject property, and asking for relief arising
therefrom, respondent invoked the jurisdiction of the trial
court. He is now estopped from challenging the
jurisdiction.
the court 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
Respondent failed to demand for specific claims for
Reimbursement as buyer in good faith in the interpleader case.
Although the alternative defense of being builders in good faith is
only permissive, the counterclaim for reimbursement of the value
of the improvements is in the nature of a compulsory counterclaim.
Thus, the failure by the private respondents to set it up bars their
right to raise it in a subsequent litigation.
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.
Res Adjudicata involves not only as to matters which were decided
in the first action, but also as to every other matter which the
parties could have properly set up in the prior suit.
In this case:
i. There was identity of causes of action since this case
involves an unpleaded compulsory counterclaim which is
now barred.
ii. It involves the same parties.
iii. Same Subject matter.
Digest Author: F. Atienza

DISPOSITION:

WHEREFORE, the instant petition is GRANTED. The decision dated

December 24, 1997 and the resolution dated March 6, 1998 of the Court of
Appeals in CA-G.R. SP No. 43895 are REVERSED and SET ASIDE. Civil
Case No. 96-1372 before the Regional Trial Court of Makati City, Branch 59,
is hereby ordered DISMISSED as against herein petitioner Edgar H. Arreza.
Costs against respondent.