GR 85868; (October, 1989) (Digest)
G.R. No. 85868 October 13, 1989
ALLIED BANKING CORPORATION, petitioner, vs. COURT OF APPEALS AND JOSELITO Z. YUJUICO, respondents.
FACTS
Joselito Yujuico obtained a loan from General Bank and Trust Company (GENBANK) in 1976. In 1977, the Central Bank ordered GENBANK’s liquidation. Allied Banking Corporation (ALLIED) subsequently acquired GENBANK’s assets and assumed its liabilities, including Yujuico’s loan. When Yujuico defaulted, ALLIED filed a collection suit in 1979. During the proceedings in 1987, Yujuico sought to file a third-party complaint against the Central Bank and the liquidator, Arnulfo Aurellano. He alleged that the Central Bank’s tortious interference in GENBANK’s affairs prevented him from performing his obligation, thereby excusing his liability.
The Regional Trial Court denied the admission of the third-party complaint. On certiorari, the Court of Appeals reversed, ordering its admission. The appellate court held that the trial court committed grave abuse of discretion, as the third-party complaint stated a cause of action for indemnity or contribution. ALLIED filed this petition, arguing the third-party complaint was improper and the cause of action had prescribed.
ISSUE
The primary issue is whether the trial court correctly denied the admission of the third-party complaint, specifically on the grounds that it fails to state a cause of action against the third-party defendants in respect of the main claim and that the alleged cause of action has prescribed.
RULING
The Supreme Court granted ALLIED’s petition and reversed the Court of Appeals. The Court clarified that a third-party complaint is proper when the third-party defendant may be liable to the defendant for all or part of the plaintiff’s claim. While the Court of Appeals correctly noted that Yujuico’s claim for damages based on alleged tortious interference could conceptually provide a basis for a third-party complaint seeking indemnity, the critical flaw was prescription.
The Court held that the cause of action for damages arising from quasi-delict prescribes in four years. The cause of action accrued on March 25, 1977, when the Monetary Board issued the resolution against GENBANK. Yujuico’s third-party complaint was filed only on June 17, 1987, well beyond the four-year prescriptive period. The Court rejected the application of the relation-back doctrine, which would have deemed the third-party complaint filed simultaneously with the original answer, as this doctrine cannot revive an already prescribed claim. Since the action had prescribed, the third-party complaint could not be admitted. The trial court’s orders denying its admission were thus reinstated.