Wack

WACK WACK GOLF AND COUNTRY CLUB V.
WON, environmental circumstances, the remedy is not 201 in the aforesaid civil case and, therefore, this
70 SCRA 165 (1976) barred. interpleader suit would compel him to establish his
rights anew, and thereby increase instead of diminish
Facts: In the instant case, the club was not so diligent litigations, which is one of the purposes of an
because it had been aware of the defendants‘ interpleader suit, with the possiblity that the benefits
Defendants separately claim to be the lawful owners conflicting claims long before its filing of the of the final judgment in the said civil case might
of the same membership fee certificates issued by the interpleader suit. It had been recognizing Tan as the eventually be taken away from him; and because the
Wack Wack Golf and Country Club. Defendant Lee lawful owner thereof. It was sued by Lee who also Corporation allowed itself to be sued to final
Won claims its ownership stemming from a decision claimed the same membership fee certificate. Yet it judgment in the said case, its action of interpleader
rendered in an earlier civil case. Meanwhile, defendant did not interplead Tan. It preferred to proceed with was filed inexcusably late, for which reason it is barred
Bienvenido Tan claims the certificates from the litigation, the earlier civil case, and to defend itself by laches or unreasonable delay.
assignment made by Swan, Culbertson, and Fritz in his therein. As a matter of fact, final judgment was
favor. It was to Swan, Culbertson and Fritz that the rendered against it and said judgment has already Doctrine: It has been held that a stakeholder's action
original membership fee certificate was issued. been executed. It is not therefore too late for it to of interpleader is too late when filed after judgment
invoke the remedy of interpleader. has been rendered against him in favor of one of the
contending claimants, especially where he had notice
In sum therefore, the plaintiff club prays that the CFI of the conflicting claims prior to the rendition of the
order the defendants to interplead and litigate their The Corporation has not shown any justifiable reason judgment and neglected the opportunity to implead
conflicting claims. why it did not file an application for interpleader in the adverse claimants in the suit where judgment was
civil case 26044 to compel the appellees herein to entered. This must be so because, once judgment is
In separate motions, however, the defendants moved litigate between themselves their conflicting claims of obtained against him by one claimant, he becomes
to dismiss the complaint on the grounds of res ownership. It was only after adverse final judgment liable to the latter.
judicata – stating that to allow an interpleader would was rendered against it that the remedy of
be tantamount to reopening the civil case involving interpleader was invoked by it. By then it was too late,
Won and collaterally attack the same –, failure to state because to be entitled to this remedy the applicant
a cause of action, and bar by prescription. must be able to show that lie has not been made
Consequently, the trial court ruled against the club. independently liable to any of the claimants. And
Hence, this petition. since the Corporation is already liable to Lee under a
final judgment, the present interpleader suit is clearly
Issue: improper and unavailing.
Whether the club was diligent in invoking the remedy

of interpleader To permit the club to bring Lee to court after the
latter‘s successful establishment of his rights in the
Held: earlier civil case would increase the suits, instead of
diminishing them as is the goal of filing an
NO. Undoubtedly, the subject matter in the instant interpleader suit.
case is proper for an interpleader suit. It must be
noted, however, that a stakeholder should use In fine, the instant interpleader suit cannot prosper
reasonable diligence—that is, by filing the because the Corporation had already been made
interpleader suit within a reasonable time after a independently liable in civil case 26044 and, therefore,
dispute has arisen without waiting to be sued by its present application for interpleader would in effect
either of the contending claimants. Otherwise, he may be a collateral attack upon the final judgment in the
be barred by laches or undue delay. But where he acts said civil case; the appellee Lee had already
with reasonable diligence in view of the established his rights to membership fee certificate

Wack

Uploaded by

Copyright:

Available Formats

Wack

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Wack

Uploaded by

Copyright:

Available Formats

WACK WACK GOLF AND COUNTRY CLUB V.

Whether the club was diligent in invoking the remedy

You might also like