GR 164517; (June, 2008) (Digest)
G.R. No. 164517; June 30, 2008
BF CORPORATION, petitioner, vs. MANILA INTERNATIONAL AIRPORT AUTHORITY, respondent.
FACTS
Petitioner BF Corporation (BF) was a member of the MTOB Consortium, which was awarded the contract to construct NAIA Terminal II by respondent Manila International Airport Authority (MIAA). Due to internal disputes, BF filed a complaint for Specific Performance, Rescission, and Damages against its consortium partners, initially including MIAA as a party-defendant. BF later amended its complaint to drop MIAA. The trial court issued orders against the lead partner, Tokyu, concerning payments and work execution. Tokyu challenged these orders via certiorari in the CA (CA-G.R. SP No. 43133), which ruled that MIAA, having been dropped, was not a proper party and had no direct interest in the intra-consortium dispute.
Subsequently, with the project nearing completion, BF filed a second amended complaint seeking to re-implead MIAA, arguing that MIAA held funds payable to the consortium from which BF claimed a share. The Regional Trial Court granted the motion and ordered MIAA’s re-impleadment. MIAA then filed a petition for certiorari (CA-G.R. SP No. 67765) before the CA, challenging this order.
ISSUE
Whether the Court of Appeals correctly annulled the RTC’s order re-impleading MIAA as a party-defendant in the intra-consortium dispute.
RULING
The Supreme Court denied BF’s petition and affirmed the CA’s decision. The legal logic centers on the nature of the dispute and the requirements for a party to be indispensably impleaded. The Court held that MIAA was not an indispensable party to the action between the consortium members. The cause of action stemmed from alleged breaches of the consortium agreement among the private corporations, a matter internal to the consortium. MIAA, as the project owner, was merely an obligor to the consortium as a single contracting entity, not to the individual members.
The Court emphasized that BF’s claim was for a share in the contract price based on its internal agreement with its partners, not a direct claim against MIAA. MIAA’s obligation was to pay the consortium, not to adjudicate or guarantee the internal distribution of funds among its members. Re-impleading MIAA would improperly compel it to involve itself in the private dispute and potentially expose it to multiple liabilities. The Court also clarified that the principle of res judicata did not apply, as the prior CA case involved different parties, subject matter, and cause of action. However, this did not affect the correctness of the CA’s finding that the RTC committed grave abuse of discretion in ordering MIAA’s re-impleadment, as no cause of action existed against MIAA in the intra-consortium suit.