G.R. Nos. 72664-65 March 20, 1990
UNITED COCONUT PLANTERS BANK, petitioner, vs. HON. INTERMEDIATE APPELLATE COURT and MAKATI BEL-AIR CONDOMINIUM DEVELOPERS, INC., respondents.

FACTS

Petitioner United Coconut Planters Bank (UCPB) filed a complaint-in-interpleader against Makati Bel-Air Condominium Developers, Inc. (Makati Bel-Air) and Altiura Investors, Inc. (Altiura) concerning a manager’s check for P494,000.00 issued by UCPB payable to Makati Bel-Air, which Altiura had purchased as payment for a condominium unit. Altiura requested UCPB to stop payment on the check, alleging a material discrepancy in the unit’s area. UCPB, informed of conflicting claims from both parties, requested Makati Bel-Air to hold presentation of the check for fifteen days to allow settlement. Upon Makati Bel-Air’s refusal, UCPB filed the interpleader suit, deposited the funds, and sought judicial guidance.
In its answer, Makati Bel-Air included a counterclaim for P5 million in damages against UCPB, alleging the bank violated its guarantee by effectively stopping payment. Subsequently, Makati Bel-Air cancelled the sale, returned the manager’s check to UCPB, and raised no objection when the trial court ordered the release of the deposited funds to Altiura. UCPB then moved to withdraw its interpleader complaint and to dismiss Makati Bel-Air’s counterclaim. The trial court granted the motion, dismissing the counterclaim. The Intermediate Appellate Court reversed, holding the counterclaim survived the dismissal of the interpleader complaint as it was based on a different cause of action.

ISSUE

Whether the dismissal of the complaint-in-interpleader also operates to dismiss Makati Bel-Air’s counterclaim for damages against UCPB.

RULING

Yes. The Supreme Court reversed the appellate court and reinstated the trial court’s dismissal of the counterclaim. The Court held that Makati Bel-Air’s counterclaim was compulsory in nature. A compulsory counterclaim arises out of or is necessarily connected with the transaction or occurrence constituting the subject matter of the opposing party’s claim. Here, the counterclaim for damages was directly and inseparably linked to UCPB’s act of filing the interpleader suit. Makati Bel-Air alleged damages precisely because UCPB resorted to interpleader instead of honoring the check.
The legal logic is that when the trial court granted UCPB’s withdrawal of the interpleader complaint as moot—a result precipitated by Makati Bel-Air’s own actions of cancelling the sale and acquiescing to the release of funds—it constituted an implicit judicial affirmation that UCPB’s recourse to interpleader was proper and justified under the circumstances. Since the bank’s action in seeking interpleader was proper, given the genuine adverse claims it faced, there could be no basis for a damages claim stemming from that very act. Furthermore, Makati Bel-Air was not a holder in due course of the manager’s check, as it was aware of the partial failure of consideration (the area discrepancy) and the adverse claim by Altiura at the time it received the check. Therefore, the compulsory counterclaim, being ancillary to the main action, was extinguished upon the dismissal of the complaint-in-interpleader.