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
Petitioner Allied Banking Corporation (ALLIED) filed a collection suit against private respondent Joselito Z. Yujuico for a loan obtained from General Bank and Trust Company (GENBANK). ALLIED acquired GENBANK’s assets, including this receivable, after the latter was ordered liquidated by the Central Bank. During the trial, 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 on the loan.
The Regional Trial Court denied the admission of the third-party complaint. On certiorari, the Court of Appeals reversed, finding grave abuse of discretion and ordering the trial court to admit the third-party complaint. The appellate court held that the claim against the third-party defendants was for indemnity or contribution in respect to the main claim, which is a proper ground for a third-party complaint under the Rules. ALLIED filed this petition, arguing the third-party complaint stated no cause of action against it, would cause delay, and that the cause of action had prescribed.
ISSUE
The primary issue is whether the trial court committed grave abuse of discretion in denying the admission of the third-party complaint, specifically considering if the claim against the third-party defendants had already prescribed.
RULING
The Supreme Court granted the petition and reversed the Court of Appeals. The Court clarified that while a third-party complaint is procedurally proper when a defendant seeks to enforce a right for contribution, indemnity, subrogation, or any other relief in respect of the plaintiff’s claim, the substantive merit of the claim must still be examined. The Court found that Yujuico’s third-party complaint was essentially an action for damages arising from quasi-delict or tortious interference, which prescribes in four years from the accrual of the cause of action.
The cause of action accrued on March 25, 1977, when the Monetary Board issued the resolution forbidding GENBANK from doing business. The third-party complaint was filed only on June 17, 1987, well beyond the four-year prescriptive period. Although the third-party complaint could relate back to the filing of the main complaint on February 7, 1979, for procedural purposes, this doctrinal relation back cannot revive a claim that was already substantively extinguished by prescription before the third-party complaint was even conceived. Since the action had clearly prescribed, the third-party complaint should not be admitted. The trial court’s orders denying its admission were thus sustained.