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Beltran vs PHHC Case Digest

Facts: Plaintiffs since they first occupied their housing units under lease from PHHC, under lease and paying monthly rentals therefor, they were assured that after 5 years of continuous occupancy they would be entitled to purchase said units. In 1991, PHHC announced that the management of the project would be transferred to GSIS in payment of PHHC's debts to GSIS. Subsequently, however, the new manager of PHHC refused to recognize all transactions and undertakings previously entered into with GSIS. Alleging that they do not know now to whom they should pay the monthly amortizations, plaintiffs filed an interpleader suit against GSIS and PHHC.

GSIS and PHHC filed a motion to dismiss for failure to state a cause of action. After hearing the motion, the court dismissed the interpleader case ruling that during the hearing, the counsel for defendant ratified the allegations in his motion and made of record that GSIS has no objection that payments on the monthly amortizations from the residents of Project 4 be made directly to PHHC. Plaintiffs appealed, contending the allegations in their complaint raise questions of fact that can be established only by answer and trial on the merits and not by a motion to dismiss heard by mere oral manifestations in open court. 

Issue: Did the trial court erred in dismissing the complaint for interpleader?

Held: No. Rule 63, section 1 of the Revised Rules of Court requires as an indispensable element that "conflicting claims upon the same subject matter are or may be made" against the plaintiff-in-interpleader "who claims no interest whatever in the subject matter or an interest which in whole or in part is not disputed by the claimants."

The record shows clearly that there were no conflicting claims by defendant corporations as against plaintiff-tenants, which they may properly be compelled in an interpleader suit to interplead and litigate among themselves. While the two defendant corporations may have conflicting claims between themselves with regard to the management, administration and ownership of Project 4, such conflicting claims are not against the plaintiffs nor do they involve or affect the plaintiffs. No allegation is made in their complaint that any corporation other than the PHHC which was the only entity privy to their lease-purchase agreement, ever made on them any claim or demand for payment of the rentals or amortization payments. Both defendant corporations were in conformity and had no dispute, as pointed out by the trial court that the monthly payments and amortizations should be made directly to the PHHC alone. Both defendant corporations were agreed that PHHC should continue receiving the tenants' payments, and that such payments would be duly recognized even if the GSIS should eventually take over Project 4 by virtue of their turnover agreement. (Beltran, et al. vs. PHHC, G.R. No. L-25138, August 28, 1969)

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