G.R. No. 214074 , February 5, 2024
PHILIPPINE NATIONAL BANK, PETITIONER, VS. MEDIAN CONTAINER CORPORATION AND ELDON INDUSTRIAL CORPORATION, RESPONDENTS.

FACTS

Respondents Median Container Corporation and Eldon Industrial Corporation filed a complaint for Reformation of Instrument against petitioner Philippine National Bank (PNB) before the Regional Trial Court (RTC). They alleged that to finance business purchases, they availed of a credit line from PNB, but instead of promissory notes, PNB induced them to sign trust receipts that did not reflect their real loan agreement, coercing payment under threat of criminal prosecution. In its Answer, PNB argued the trust receipts reflected the true agreement and filed a counterclaim for PHP 31,059,616.29, representing respondents’ unpaid obligations under the trust receipts. PNB also sought to implead Spouses Carlos and Fely Ley, officers of Median, to hold them solidarily liable. The RTC dismissed PNB’s counterclaim without prejudice, ruling it was a permissive counterclaim over which it did not acquire jurisdiction due to PNB’s failure to pay the required docket fees and file a certificate of non-forum shopping. The RTC also denied the motion to implead. The Court of Appeals affirmed the RTC’s rulings, holding the counterclaim was permissive as the evidence and issues for the reformation action differed from those for the collection claim. PNB filed the present Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals committed reversible error in upholding the RTC’s dismissal of PNB’s counterclaim and denial of its motion to implead Spouses Ley.

RULING

The Petition is without merit. The Supreme Court found no reversible error in the CA’s decision. The Court ruled that PNB’s counterclaim for collection of sum of money based on the trust receipts is permissive, not compulsory, in relation to respondents’ action for reformation of instrument. The evidence required to establish the parties’ real agreement (for reformation) is different from the evidence needed to prove respondents’ failure to fulfill obligations under the trust receipts (for collection). The issues in the two claims are also distinct: reformation concerns the true intention of the parties, while the counterclaim concerns liability for payment. As a permissive counterclaim, PNB was required to pay the prescribed docket fees for the RTC to acquire jurisdiction. Its failure to do so warranted the dismissal of the counterclaim. The denial of the motion to implead Spouses Ley was likewise proper since the RTC did not acquire jurisdiction over the permissive counterclaim to which they were to be impleaded. The Court noted that PNB is not without recourse, as it may file a separate action for collection. Furthermore, the issues raised involved a review of factual determinations, which is not permissible in a Rule 45 petition limited to questions of law.