Interpleader case under Rule 62

G.R. No. 197311 - STRADCOM CORPORATION, represented by its President CEZAR T.

QUIAMBAO, petitioner, versus HON. EDGAR DALMACIO SANTOS, as Presiding Judge of the RTC-
Quezon City, Branch 222, REPUBLIC OF THE PHILIPPINES, through the LAND TRANSPORTATION
OFFICE represented by ASSISTANT SECRETARY VIRGINIA TORRES and BONIFACIO C. SUMBILLA,
representing himself to be the representative of Stradcom Corporation, respondents.crala
FACTS:
The Quiambao group filed the instant motion for reconsideration submitting, among others,
that this Court should have ordered the dismissal of the Interpleader case.
The instant motion for reconsideration lacks merit.
It bears reiterating that what the Republic through the OSG filed before the Regional Trial Court
of Quezon City is not an intra-corporate case, as contended by the Quiambao group, but an
Interpleader case under Rule 62 of the 1997 Rules of Civil Procedure, as amended. Section 1,
Rule 62, pertinently provides:
SECTION 1. When interpleader proper. Whenever conflicting claims upon the same subject
matter are or may be made against a person who claims no interest whatever in the subject
matter, or an interest which in whole or in part is not disputed by the claimants, he may bring
an action against the conflicting claimants to compel them to interplead and litigate their
several claims among themselves.
Having passed upon the basic issues, we find no reason to discuss the other arguments raised in
the motion. Suffice to say, the Quiambao group's motion for reconsideration simply reiterates
the arguments already considered by the Court and the motion raises no new and substantial
arguments requiring a reconsideration of the Court's August 23, 2011 Resolution.cralaw
WHEREFORE, the Motion for Reconsideration filed by petitioner Stradcom Corporation,
represented by its President Cezar T. Quiambao, is DENIED WITH FINALITY."






G.R. No. 159301: September 14, 2011
OSALINDA DELESTE, PETITIONER v. ARACELI EBARLE-THOMMES AND PRIVATE ENTERPRISE
CORPORATION, RESPONDENTS.
FACTS:
On January 10, 1977, one Ismael, Salcedo filed a petition for re-adjudication vis-a-vis Lot No.
639 and Lot No. 2051 in the RTC (LRC Case No. 1561). On February 16, 1977, with the re-
adjudication having been granted, Decree No. 165298 was issued, and Original Certificate of
Title (OCT) No. 0-686 was issued in the name of Salcedo.
Salcedo's title did not go unchallenged for long, however, because Ebarle-Thommes surfaced to
claim dominion over Lot 639. On December 22, 1977, Ebarle-Thommes brought a petition for
review and for the annulment of the proceedings and of Decree No. N-165298 in the RTC of
Misamis Oriental, assigned to Branch 20 (Civil Case No. 10553), but the petition was dismissed
on October 13, 1983 for failure to prosecute. Although she moved to lift the order of dismissal
on the same date, the RTC denied her motion on August 15, 1990. However, on November 21,
1990, the RTC set aside the dismissal upon her motion for reconsideration.
ISSUE:
The subject of the appeal in the CA had concerned only whether the dismissal of the
interpleader action had been proper or not.
The dismissal of the appeal of Ebarle-Thommes is but a technicality to be overlooked in order
not to obstruct the judicious resolution of the more substantial right of the parties to have their
conflicting claims of ownership settled with finality. As we held in Aguam v. Court of Appeals,
"(l) itigations must be decided on their merits and not on technicality. Every party litigant must
be afforded the amplest opportunity for the proper and just determination of his cause, free
from the unacceptable plea of technicalities.
WHEREFORE, we AFFIRM the decision dated April 11, 2002 promulgated in C.A.-G.R. CV. No.
49920.
Costs of suit to be paid by the petitioner.
SO ORDERED.

Dela Cruz vs. Planters Products, Inc., 691 SCRA 28, February 18, 2013
Case Title: SPOUSES QUIRINO V. DELA CRUZ and GLORIA DELA CRUZ, petitioners, vs. PLANTERS
PRODUCTS, INC., respondent.

Justification in order to warrant the grant of attorneys fees to the winning party, viz.: As to attorneys
fees, the general rule is that such fees cannot be recovered by a successful litigant as part of the
damages to be assessed against the losing party because of the policy that no premium should be placed
on the right to litigate. Indeed, prior to the affectivity of the present Civil Code, such fees could be
recovered only when there was a stipulation to that effect. It was only under the present Civil Code that
the right to collect attorneys fees in the cases mentioned in Article 2208 of the Civil Code came to be
recognized. Such fees are now included in the concept of actual damages.
With the matter of attorneys fees in its own decision. The award of attorneys fees is deleted because
of the absence of any factual and legal justification being expressly stated by the CA as well as by the
RTC. To start with, the Court has nothing to review if the CA did not tender in its decision any
justification of why it was awarding attorneys fees. The award of attorneys fees must rest on a factual
basis and legal justification stated in the body of the decision under review. Absent the statement of
factual basis and legal justification, attorneys fees are to be disallowed.
Forbearance of money or otherwise, shall be 12% per annum from such finality until its satisfaction.
(Manzano vs. Lazaro, 669 SCRA 209 [2012 ]) While contracts of adhesion may be struck down as void
and unenforceable for being subversive of public policy, the same can only be done when, under the
circumstances, the weaker party is imposed upon in dealing with the dominant bargaining party and is
reduced to the alternative of taking it or leaving it, completely depriving the former of the opportunity
to bargain on equal footing.
Consequences to them of the application of the pertinent law and jurisprudence, no matter how
unfavorable to them. IV. Attorneys fees to be deleted In granting attorneys fees, the RTC merely relied
on and adverted to PPIs allegation that the failure of the petitioners to comply with their
obligations under the contracts had compelled *them+ to hire the services of a counsel for which it had
agreed to an attorneys fee equivalent to 25% of the total amount recovered exclusive of appearance
fee of P1,500.00 as its sole basis for holding the petitioners liable to pay P20,000.00 as attorneys fee
and cost of litigation. In affirming the RTC thereon, the CA did not even mention or deal.
Circumstances do not warrant a conclusion that they were not debtors of PPI under the credit line
agreement. WHEREFORE, the Court AFFIRMS the Decision promulgated on April 11, 2003 by the Court of
Appeals, subject to the MODIFICATIONS that: (a) the rate of interest is 12% per annum reckoned from
the filing of the complaint until full payment; and (b) the award of attorneys fees is deleted. The
petitioners shall pay the costs of suit. SO ORDERED. Sereno (C.J., Chairman), Leonardo-De Castro,
Villarama, Jr. and Reyes, JJ., concur. Judgment affirmed with modifications. Notes.After a judgment
has become final and executory, the rate of legal interest, whether the obligation was in the form of a
loan.
Issue: PETITION for review on certiorari of the decision and resolution of the Court of Appeals.
1. Mercantile Law; Trust Receipts Law; Under Section 4 of the Trust Receipts Law, the sale of goods by a
person in the business of selling goods for profit who, at the outset of the transaction, has, as against
the buyer, general property rights in such goods, or who sells the goods to the buyer on credit, retaining
title or other interest as security for the payment of the purchase price, does not constitute a trust
receipt transaction and is outside the purview and coverage of the law.
2. Civil Law; Contracts of Adhesion; A contract of adhesion prepared by one party, usually a corporation,
is generally not a one-sided document as long as the signatory is not prevented from studying it before
signing.
3. Remedial Law; Evidence; Entries Made in the Course of Business; Entries made in the course of
business enjoy the presumption of regularity.
4. Civil Law; Interest Rates; Once a judicial demand for payment has been made, however, Article 2212
of the Civil Code should apply, that is: Interest due shall earn legal interest from the time it is judicially
demanded, although the obligation may be silent upon this point.
5. Same; Same; In Eastern Shipping Lines, Inc. vs. Court of Appeals, 234 SCRA 78 (1994), the Supreme
Court defined a formula for the computation of legal interest for the guidance of the Bench and the Bar.
6. Same; Damages; Attorneys Fees; The award of attorneys fees must rest on a factual basis and legal
justification stated in the body of the decision under review.

WHEREFORE, the Court AFFIRMS the Decision promulgated on April 11, 2003 by the Court of Appeals,
subject to the MODIFICATIONS that: (a) the rate of interest is 12% per annum reckoned from the filing of
the complaint until full payment; and (b) the award of attorneys fees is deleted. The petitioners shall
pay the costs of suit.