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The following post does not create a lawyer-client relationship between Alburo Alburo and Associates Law Offices (or any of its lawyers) and the reader. It is still best for you to engage the services of a lawyer or you may directly contact and consult Alburo Alburo and Associates Law Offices to address your specific legal concerns, if there is any.
Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
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. (Section 1, Rule 62 of the Revised Rules of Civil Procedure)
In the case of Bureau of Internal Revenue v. Tico Insurance Company, Inc. (G.R. No. 204226, April 18, 2022), the Supreme Court held that the special civil action of interpleader is designed to protect a person against double vexation in respect of a single liability.
It requires, as an indispensable requisite, that conflicting claims upon the same subject matter are or may be made against the stakeholder (the possessor of the subject matter) who claims no interest whatsoever in the subject matter or an interest which in whole or in part is not disputed by the claimants. Through this remedy, the stakeholder can join all competing claimants in a single proceeding to determine conflicting claims without exposing the stakeholder to the possibility of having to pay more than once on a single liability. In short, the remedy of interpleader, when proper, merely provides an avenue for the conflicting claims on the subject matter to be threshed out in an action.
Upon the filing of the complaint, the court shall issue an order requiring the conflicting claimants to interplead with one another. If the interests of justice so require, the court may direct in such order that the subject matter be paid or delivered to the court. (Section 2, Rule 62 of the Revised Rules of Civil Procedure)
Within the time for filing an answer, each claimant may file a motion to dismiss on the ground of impropriety of the interpleader action or on other appropriate grounds specified under Rule 16. The period to file an answer shall be tolled and if the motion is denied, the movant may file his answer within the remaining period, but which shall not be less than five (5) days in any event, reckoned from the notice of denial. (Section 4, Rule 62 of the Revised Rules of Civil Procedure)
Each claimant shall file his answer setting forth his claim within fifteen (15) days from service of summons upon him, serving a copy thereof upon each of the other conflicting claimants who may file their reply thereto as provided by these Rules. If any claimants fails to plead within the time herein fixed, the court may, on motion, declare him in default and thereafter render judgment barring him from any claim in respect to the subject matter. (Section 5, Rule 62 of the Revised Rules of Civil Procedure)
A successful litigant who has secured a final judgment in its favor cannot be impleaded by its defeated adversary in an interpleader suit, and compelled to prove its claim anew against other adverse claimants, as that would in effect be a collateral attack upon the judgment. In other words, an action for interpleader may not be utilized to circumvent the immutability of a final and executory judgment. It is settled that when a decision has attained finality, it may no longer be modified in any respect, even if the modification is meant to correct erroneous conclusions of fact and law. The doctrine is grounded on the public policy that at the risk of occasional errors, litigation should end at some definite date fixed by law. This is a fundamental principle in our justice system, without which there would be no end to litigations.
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Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding legal services, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/ 09175772207/ 09778050020.
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