G.R. Nos. 154470-71 and 154589-90; September 24, 2012
BANK OF COMMERCE, Petitioner, vs. PLANTERS DEVELOPMENT BANK and BANGKO SENTRAL NG PILIPINAS, Respondents. BANGKO SENTRAL NG PILIPINAS, Petitioner, vs. PLANTERS DEVELOPMENT BANK, Respondent.

FACTS

Planters Development Bank (PDB) acquired Central Bank (CB) bills from Bank of Commerce (BOC), evidenced by Detached Assignments. In a subsequent transaction, PDB sold Treasury Bills to BOC but delivered the CB bills instead, while retaining the Detached Assignments. BOC later sold and reacquired these bills through various intermediaries. Separately, PDB acquired another set of CB bills from Rizal Commercial Banking Corporation and transferred them, ultimately leading to BOC’s acquisition. Upon learning of the transfers, PDB notified the Bangko Sentral ng Pilipinas (BSP) of its claim over the bills based on the Detached Assignments, requesting the BSP to record its claim and withhold payment from any presenter not a holder in due course. The BSP refused, citing its regulations requiring presentation of the bond for transfer.
PDB filed a petition with the Regional Trial Court (RTC) to compel the BSP to record its claim and to declare it the rightful owner. BOC filed an answer with a compulsory counterclaim asserting ownership and seeking damages. The BSP filed a motion to interplead, requesting the court to order PDB and BOC to litigate their conflicting claims so it could be discharged from liability. The RTC dismissed PDB’s petition, BOC’s counterclaim, and the BSP’s interpleader, and denied their motions for reconsideration.

ISSUE

Whether the RTC erred in dismissing the BSP’s interpleader and BOC’s compulsory counterclaim.

RULING

Yes, the RTC erred. The Supreme Court reinstated the BSP’s interpleader and BOC’s compulsory counterclaim. An interpleader is proper when a party, like the BSP, holds property to which it claims no interest but is confronted with conflicting claims from other parties, exposing it to double vexation. The BSP, as the issuer and eventual payer of the CB bills, was a legitimate stakeholder faced with adverse claims from PDB and BOC over the same instruments. Dismissing the interpleader forced the BSP to independently determine the rightful owner—a judicial function—and risk multiple liabilities, which is precisely the situation interpleader seeks to avoid.
Regarding BOC’s compulsory counterclaim, the RTC’s dismissal for non-payment of docket fees was incorrect. A compulsory counterclaim arises from the same transaction or occurrence as the opposing party’s claim and does not require an independent jurisdictional basis. At the time of filing, the rules did not require payment of docket fees for compulsory counterclaims. The counterclaim, seeking a declaration of BOC’s ownership and damages stemming from the same CB bill transactions, was compulsory. Its dismissal on a procedural technicality, despite being intrinsically linked to PDB’s main action, constituted a reversible error. The case was remanded to the RTC for further proceedings on the interpleader and the compulsory counterclaim.