GR L 2097; (October, 1950) (Digest)
G.R. No. L-2097; October 16, 1950
ORIENTAL SAWMILL, plaintiff-appellant, vs. MANUEL TAMBUNTING and ANGEL DE LEON ONG, defendants-appellees.
FACTS
Plaintiff Oriental Sawmill, a sublessee of a vacant lot in Manila, filed an action for interpleader against defendants Manuel Tambunting and Angel de Leon Ong, who have conflicting claims over the rental payments for the lot. The property was originally owned by Tambunting, who allegedly sold it to Ong in 1944. Tambunting then leased back the property from Ong and subleased parts of it, including to Oriental Sawmill. There are multiple pending civil cases between Tambunting and Ong concerning the ownership of the property. In a prior ejectment suit in the Municipal Court of Manila filed by Tambunting against Oriental Sawmill’s manager, Ong was allowed to intervene. Judgment was rendered in favor of Tambunting, but Ong’s appeal was dismissed for being filed out of time. The municipal court’s decision did not resolve the ownership issue between Tambunting and Ong. Oriental Sawmill, uncertain of whom to pay the rent, deposited the amount in court and filed this interpleader action. The lower court dismissed the complaint on the ground of res adjudicata.
ISSUE
Whether the action for interpleader filed by Oriental Sawmill is proper under the circumstances.
RULING
Yes. The Supreme Court reversed the order of dismissal and remanded the case for further proceedings. An action for interpleader is proper when a person, such as a lessee or sublessee, is in doubt as to whom payment should be made due to conflicting claims over the property. The prior ejectment suit did not constitute res adjudicata on the ownership issue because the municipal court lacked jurisdiction to settle questions of ownership. The conflicting claims of Tambunting and Ong, which are the subject of separate pending litigation, give Oriental Sawmill reasonable grounds for doubt, justifying the interpleader action. The Court cited precedents, including Pagkalinawan v. Rodas and *De Jesus v. Sociedad Arrendataria de Galleras de Pasay*, which support the propriety of interpleader in similar situations.
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