Reyes, Jr. v. Rivera
REITERATIONFacts
1. The Antecedents: The underlying dispute involves competing claims of ownership over the Venancia Building in Baguio City. Civil Case No. 2817, filed by petitioner Florencio Reyes, Jr. as administrator of his father's estate, sought recovery of possession based on a contract of sale between the petitioner's predecessor and respondent Francisco San Pedro. Concurrently, Civil Case No. 167-R was an interpleader case initiated by tenants Romeo Espinosa and Aurora Cervantes, who sought court intervention to determine who among petitioner Reyes and respondent San Pedro was entitled to receive rental payments for the building. A separate matter, Civil Case No. 288-R, concerned an appeal from a municipal court decision ordering the City of Baguio to vacate a parcel of land. 2. Procedural History: The case reached the Supreme Court via a petition for certiorari, mandamus, and prohibition. Petitioner sought to annul an order by respondent Judge Rivera (February 6, 1985) allowing private respondent Genaro Bulotano to withdraw P19,000.00 deposited in Civil Case No. 167-R. Petitioner also challenged an earlier order by respondent Judge Doria (January 9, 1985) consolidating Civil Case No. 167-R with Civil Case No. 2817. The Supreme Court had previously issued a temporary restraining order on September 25, 1985, enjoining Judge Rivera from proceeding with the consolidated cases and related matters, except to comply with an Intermediate Appellate Court decision. Attempts to consolidate this case with other related Supreme Court petitions were unsuccessful as those petitions had either been denied or referred to lower courts. 3. The Petition: The petitioner invoked the Supreme Court's original jurisdiction through a petition for certiorari, mandamus, and prohibition, seeking to nullify specific orders from respondent judges. The primary arguments focused on the alleged grave abuse of discretion by respondent Judge Rivera in allowing the withdrawal of funds deposited in an interpleader case, contending that such funds were custodia legis and not subject to execution from a separate case. Petitioner also argued that the consolidation of the interpleader case with the ownership dispute was proper, but the subsequent order regarding the withdrawal of deposited rentals was erroneous. Furthermore, petitioner sought the inhibition of Judge Rivera from hearing the consolidated cases due to potential bias, citing an ongoing administrative case against the judge.
Issue(s)
Whether the consolidation of Civil Case No. 167-R with Civil Case No. 2817 was attended by grave abuse of discretion. Whether respondent Judge Rivera gravely abused his discretion in allowing the withdrawal of the P19,000.00 deposited in Civil Case No. 167-R. Whether respondent Judge Rivera should be inhibited from hearing the consolidated cases.
Ruling
The Court resolved to ANNUL and SET ASIDE the February 6, 1985 order of respondent Judge Rivera in Civil Case No. 167-R, ORDERED respondent Genaro Bulotano to RETURN the amount released to him, ORDERED respondent Judge Rivera to INHIBIT himself from hearing Civil Case Nos. 2817, 167-R and 288-R, and ORDERED the Executive Judge of the Regional Trial Court of Baguio City to RE-RAFFLE the said cases to other branches. The temporary restraining order issued on September 25, 1985, was made permanent.
Ratio Decidendi
On the consolidation of Civil Case No. 167-R with Civil Case No. 2817: The Court held that the consolidation was not attended by grave abuse of discretion amounting to lack or excess of jurisdiction. The issue in the interpleader case (Civil Case No. 167-R), which is who is entitled to receive rentals, is necessarily subsumed by the larger issue in the recovery of possession case (Civil Case No. 2817), which is who is the lawful owner of the building. Therefore, consolidating the two cases was not only proper but also in compliance with the policy against multiplicity of suits. The Court found no grave abuse of discretion in the order of respondent Judge Doria. On the withdrawal of the P19,000.00 deposit: The Court found that respondent Judge Rivera gravely abused his discretion when he allowed the withdrawal of the P19,000.00. The amount deposited by Romeo Espinosa in Civil Case No. 167-R was specifically for rentals due during the pendency of the interpleader case and was intended to be paid to whoever would be adjudged entitled to collect the rentals. Crucially, the amount deposited was property in custodia legis, meaning it was under the custody of the court. Settled jurisprudence dictates that property in custodia legis cannot be subjected to a writ of execution from another case. By allowing the withdrawal of the deposit based on a writ of execution from a Municipal Trial Court case, respondent Judge Rivera acted contrary to this established legal principle. The Court cited Piliin v. Jocson, Asia Banking Corp. v. Elser, and Alo v. Nolasco in support of this principle. On the inhibition of respondent Judge Rivera: The Court ordered the inhibition of respondent Judge Rivera not solely because of the finding of grave abuse of discretion, but also to prevent any perception of bias. This was particularly relevant given that the petitioner had filed an administrative case against Judge Rivera for serious misconduct and inefficiency concerning his assailed order. Inhibiting the judge would serve to close the door on any potential accusations of bias and ensure impartiality in the disposition of the cases.
Main Doctrine
A deposit made in court in an interpleader case to answer for rentals due during the pendency of the case is property in custodia legis and cannot be reached by execution from another case.