Traders Royal Bank v. Intermediate Appelate Court
REITERATIONFacts
1. The Antecedents: Petitioner Traders Royal Bank initiated a lawsuit against Remco Alcohol Distillery, Inc. for a substantial debt, securing a writ of attachment against Remco's assets. Among the attached properties were approximately 4,600 barrels of aged or rectified alcohol located at Remco's premises. Respondent La Tondeña, Inc. subsequently filed a third-party claim, asserting ownership over the attached alcohol, alleging it had made significant advances to Remco that remained outstanding. 2. Procedural History: Following the third-party claim, La Tondeña, Inc. filed a complaint-in-intervention in the original Pasay City case, which was later withdrawn. The Pasay Court initially allowed La Tondeña to withdraw the alcohol but later reconsidered, declaring the alcohol to be Remco's property and denying the intervention. La Tondeña then filed a separate action in the Regional Trial Court of Malolos, Bulacan, seeking ownership of the attached alcohol and an injunction. The Bulacan court granted the injunction, declaring La Tondeña the owner. Traders Royal Bank petitioned the Intermediate Appellate Court for certiorari and prohibition to annul the Bulacan court's order and injunction, but this petition was dismissed. The Intermediate Appellate Court affirmed the Bulacan court's decision, leading to the present petition. 3. The Petition: Petitioner Traders Royal Bank contends that the Regional Trial Court of Bulacan acted without jurisdiction by issuing an injunction that interfered with the writ of attachment previously issued by the Pasay City Regional Trial Court. Petitioner argues this constitutes an illegal interference with a coordinate court's authority. The petition seeks to annul the Bulacan court's order and injunction, prohibit further cognizance of the case by the Bulacan court, and compel the return of the disputed alcohol.
Issue(s)
Whether the Regional Trial Court of Malolos, Bulacan, acted without jurisdiction in issuing a writ of preliminary injunction enjoining the sale of property previously levied upon by the sheriff pursuant to a writ of attachment issued by the Regional Trial Court of Pasay City. Whether the filing of a third-party claim and a motion to intervene in the original attachment case bars a subsequent independent action by the third-party claimant to vindicate ownership.
Ruling
The petition is devoid of merit. The Supreme Court affirmed the decision of the Intermediate Appellate Court, upholding the authority of the Regional Trial Court of Malolos to issue the injunction.
Ratio Decidendi
On the issue of jurisdiction and interference with coordinate courts: The Court held that the action filed by La Tondeña, Inc., as a third-party claimant, before the Regional Trial Court of Bulacan, asserting ownership over the property levied upon, is sanctioned by Section 14, Rule 57 of the Rules of Court. This rule explicitly provides a remedy for a person claiming ownership of property under attachment, allowing them to file a separate and independent action to vindicate their claim. The Court clarified that while property in custodia legis cannot generally be interfered with, this rule applies when the property belongs to the defendant or the defendant has a proprietary interest. When a sheriff seizes a stranger's property, the rule does not apply, and interference with the custody is not interference with another court's order of attachment. The Court cited Manila Herald Publishing Co., Inc. vs. Ramos to support the principle that a judge trying an action by a third-party claimant may render judgment ordering the sheriff to deliver the property or desist from seizing it, and may issue interlocutory orders to preserve the subject matter of the suit or protect parties' interests. The objection that one judge would interfere with another judge's actuations was deemed superficial, as jurisdiction over an action includes jurisdiction over incidental interlocutory matters necessary to preserve the subject matter or protect interests. On the effect of filing a third-party claim and motion to intervene: The Court rejected the petitioner's argument that La Tondeña's voluntary submission to the jurisdiction of the Pasay Court by filing a motion to intervene barred the action before the Bulacan Court. The Court reiterated that intervention is not exclusive but cumulative and suppletory to the right to bring an independent suit, citing Manila Herald Publishing Co., Inc. v. Ramos, Zulueta, et al. v. Munoz, et al., and Bayer Phil., Inc. v. Agana. Furthermore, the denial or dismissal of a third-party claim to property levied upon does not operate to bar a subsequent independent action by the claimant to establish their right to the property, even if they failed to appeal the order denying their original third-party claim, as established in Potenciano v. Dineros.
Main Doctrine
A Regional Trial Court may issue an injunction to enjoin the sale of property previously levied upon by a sheriff pursuant to a writ of attachment issued by another Regional Trial Court, when such injunction is sought by a third-party claimant asserting ownership over the attached property. This is a proper and independent action to vindicate the claimant's ownership rights, distinct from the original attachment proceeding.