GR 214074 Lazaro Javier (Digest)
G.R. No. 214074 , February 5, 2024
PHILIPPINE NATIONAL BANK, PETITIONER, VS. MEDIAN CONTAINER CORPORATION AND ELDON INDUSTRIAL CORPORATION, RESPONDENTS.
FACTS
This is a dissenting opinion. The main case involves a complaint filed by respondents Median Container Corporation and Eldon Industrial Corporation against petitioner Philippine National Bank (PNB) for the reformation of a trust agreement into a mere contract of loan. In response, PNB filed a counterclaim seeking to collect the amount due under the same trust agreement. The central procedural dispute is whether PNB’s counterclaim is compulsory or permissive.
ISSUE
Whether the counterclaim of PNB for collection of the amount due under the trust agreement is a compulsory counterclaim to the respondents’ complaint for reformation of the same agreement.
RULING
The dissenting opinion argues that PNB’s counterclaim is compulsory, not permissive. The reasoning is based on the following:
1. Precedent on Reformation as Compulsory Counterclaim: Citing Gojo v. Goyala, the opinion states that a claim for reformation of an instrument is a compulsory counterclaim to a complaint alleging the fulfillment of contract conditions (like the expiration of a right to repurchase), as both arise from the same transaction or occurrence. Here, the counterclaim for collection arises from the very trust agreement that respondents seek to reform, and it is directly connected to PNB’s defense that the contract is one of trust.
2. Test of Res Judicata: Applying the factor that a counterclaim is compulsory if a judgment in the main action would bar a subsequent suit on the defendant’s claim under the principle of res judicata, the opinion cites Spouses Abines v. Bank of the Philippine Islands. It was ruled there that a judgment in a collection case would be res judicata in a reformation case concerning the same agreements, as they involve the same evidence and subject matter.
3. Judicial Economy: Treating the counterclaim as compulsory promotes judicial efficiency by resolving all related issues in a single proceeding.
Therefore, the dissenting opinion concludes that PNB’s counterclaim is compulsory and votes to GRANT PNB’s Petition for Review on Certiorari and REVERSE the assailed Court of Appeals rulings.