GR 170498; (January, 2013) (Digest)
G.R. No. 170498 ; January 9, 2013
METROPOLITAN BANK & TRUST COMPANY, Petitioner, vs. ABSOLUTE MANAGEMENT CORPORATION, Respondent.
FACTS
Sherwood Holdings Corporation (SHCI) sued Absolute Management Corporation (AMC) for sum of money for alleged undelivered goods, with payments made via crossed checks payable to AMC but received by its General Manager, Jose L. Chua. After Chua’s death, AMC, in its answer, filed a third-party complaint against Metrobank, alleging the bank deposited these crossed checks into the account of Ayala Lumber & Hardware, a sole proprietorship owned by Chua, without AMC’s consent. Metrobank, in turn, sought to file a fourth-party complaint against the Estate of Jose L. Chua, claiming that if it were held liable to AMC, the estate should reimburse it.
The Regional Trial Court (RTC) denied the admission of Metrobank’s fourth-party complaint. It ruled the claim was essentially for reimbursement based on quasi-contract (cobro de lo indebido), constituting a money claim against the estate that must be filed in the pending judicial settlement proceedings for Chua’s estate under Section 5, Rule 86 of the Rules of Court. The Court of Appeals affirmed this ruling.
ISSUE
Whether the RTC correctly denied the admission of Metrobank’s fourth-party complaint against Chua’s estate on the ground that it is a money claim required to be filed in the estate settlement proceedings.
RULING
Yes, the Supreme Court affirmed the denial. The core legal principle is the distinction between the general jurisdiction of a court in an ordinary civil action and the limited, exclusive jurisdiction of a probate court over claims against a deceased’s estate. Metrobank’s fourth-party complaint sought contingent reimbursement from Chua’s estate, characterizing it as arising from quasi-contract. Under Section 5, Rule 86, all claims for money against the estate, whether arising from contract, quasi-contract, tort, or crime, must be filed in the estate settlement proceedings. This procedure ensures orderly settlement, prevents fraudulent claims, and protects creditors by subjecting claims to a single forum.
The Court rejected Metrobank’s argument that its claim was merely contingent or an alternative defense. The nature of the claim as one for payment from the estate is controlling. Filing it in the ordinary civil case would circumvent the specific rules governing estate claims, potentially leading to conflicting decisions and disrupting the orderly administration of the estate. The proper remedy for Metrobank was to file its money claim in the existing special proceedings for Chua’s estate in Pasay City, not as a fourth-party complaint in the Quezon City RTC. The lower courts correctly disallowed the pleading to uphold the procedural regime for claims against a decedent’s estate.