G.R. No. L-33255 November 29, 1972
ARTURO BALBASTRO, JOSE PEREZ, EDGARDO DE LA CRUZ, LEONARDO VILLANUEVA and CONSORCIA HALILI, petitioners, vs. COURT OF APPEALS, HON. WALFRIDO DE LOS ANGELES, in his capacity as Judge of the Court of First Instance of Rizal, Quezon City, Branch IV, and FRANCISCO E. FERNANDEZ, respondents.

FACTS

The case originated from an interpleader suit filed by three lessees of a 10-door apartment in Quezon City. The lessees, uncertain whether to pay rentals to defendant Angela M. Butte or defendant Francisco E. Fernandez due to their conflicting ownership claims, consigned the rentals to court. Private respondent Fernandez, in his answer, sought authority to collect and deposit the rents pending litigation. Subsequently, Fernandez filed a pleading designated as a “Third-Party Complaint” against the petitioners, who were the lessees of the remaining seven doors of the same apartment building and who refused to recognize his authority to collect rents.
Petitioners moved to dismiss this Third-Party Complaint, arguing it violated Section 12, Rule 6 of the Revised Rules of Court on third-party procedure and failed to state a cause of action. The trial court denied their motion and subsequent motion for reconsideration. The Court of Appeals sustained the trial court, prompting petitioners to elevate the case via certiorari, contending the respondent judge committed grave abuse of discretion.

ISSUE

Whether the respondent judge committed grave abuse of discretion in allowing the inclusion of petitioners as parties in the interpleader case through the “Third-Party Complaint” filed by respondent Fernandez.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The Court clarified that while the pleading was mislabeled as a “Third-Party Complaint” under Rule 6, Section 12—which typically involves a defendant claiming a right to contribution, indemnity, subrogation, or other relief from a person not a party to the action—its allowance was justified under the broader principles of permissive joinder of parties.
The legal logic centers on trial convenience and the efficient administration of justice. The Court emphasized that rules on joinder should be applied with flexibility. Here, all lessees of the 10-door apartment, including the original plaintiffs and the petitioners, shared an identical legal dilemma: determining the rightful recipient of their rentals amidst the same ownership dispute between Butte and Fernandez. Joining all lessees in a single proceeding would simplify procedure, expedite litigation, reduce expenses, and avoid multiplicity of suits. This joinder is expressly sanctioned by Rule 3, Section 6 of the Revised Rules, which permits joinder when there is a common question of law or fact.
Consequently, the trial court’s action, aimed at settling the common issue for all tenants in one proceeding, was a proper exercise of its discretion. The misnomer of the pleading did not invalidate the court’s order, as the substance—the joinder of necessary parties for a complete resolution—controlled over its form. No grave abuse of discretion was found.