You are on page 1of 2

Makati Development Corporation vs. Pedro C. Tanjuatco and Concrete Aggregates Inc.

March 25, 1969

Doctrine:
1. The failure of section 19 of Rule 5 of the present Rules of Court to make its Rule 63, on
interpleading, applicable to inferior courts, merely implies that ,the same are not bound to follow
Rule 63 in dealing with cases of interpleading, but may apply thereto the general rules on procedure
applicable to ordinary civil action in said courts.
2. Where the conflicting claims involve the right to receive a particular sum, the amount of the sum
claimed determines jurisdiction.

Summary:
Makati Development Corp (MDC) and Pedro Tanjuatco (Tanjuatco) entered into a contract where Tanjuatco
would build a water reservoir. Before MDC made the final payment to Tanjuatco, the suppliers of Tanjuatco
called the attention of MDC of Tanjuatcos unpaid account. MDC withheld the payment and filed an action
with CFI to compel Tanjuatco and Concrete Aggregates (Concrete), one of his suppliers to interplead their
conflicting claims because MDC was not sure whether its final payment should be paid to Tanjuatco or
Concrete. Granted. MDC filed an appeal with SC because he claims that the subj matter of the case is to
compel the defendants to litigate among themselves and not the sum. SC held that the CFI has no jurisdiction
to settle the interpleader as the amount is only 5k (must be filed in MTC). If di niyo gets, check orig.

Facts:
On Feb 21, 1963, MDC and Tanjuatco entered into a contract where Tanjuatco would construct a reinforced
concrete covered water reservoir, office and pump house and water main at Forbes Park, Makati, Rizal, and
furnishing the materials necessary.

The suppliers called the attention of MDC of the unpaid bills of Tanjuatco. So

Before making the final payment, MDC asked the suppliers of materials whether Tanjuatco had settled his
accounts with them.

Concrete Aggregates, the supplier, claims Tanjuatco owes them P5,198.75 for the cost of transit-mixed
concrete.

MDC, with consent from Tanjuatco, withheld the final payment because of the subsequent failure of
Tanjuatco to settle the issue with Concrete.

On Sept. 16, 1955, MDC instituted an action in CFI Rizal against Tanjuatco and Concrete to compel them to
interplead their conflicting claims.

Tanjuatco moved to DISMISS on the ground of lack of jurisdiction over the subject matter because the
involved amount being less than P10,000. -GRANTED by CFI.

MDC filed an appeal w/SC claiming that the subject matter of the case is not the P5,198.75 but the right to
compel the defendants to litigate among themselves in order to protect MDC against a double vexation in
respect to one liability.

Issue: Whether the CFI has jurisdiction? -NO

Held:
The Court held that without doubt, MDC can compel Concrete and Tanjuatco to interplead among
themselves. However, the Court held that CFI has no jurisdiction because the real object of the action to
determine who among the Tanjuatco and Concrete is entitled to collect the payment of MDC, which is not
within the jurisdiction of CFI because the subject matter of the case is only 5k. In another case, Concrete
sued Tanjuatco for the recovery of the P5,198.75, and the decision therein will settle the question as to who
has a right to the sum withheld by MDC. lawphi1.et
MDC in asserting the jurisdiction of the CFI relies upon Rule 63 of the present Rules of Court,
prescribing the procedure in cases of interpleading, and section 19 of Rule 5, which omits the Rules
on Interpleading among those made applicable to inferior courts. However, the jurisdiction of our
courts over the subject-matter of justiciable controversies is governed by Rep. Act No. 296, as
amended, pursuant to which municipal courts shall have exclusive original jurisdiction in all civil
cases "in which the demand, exclusive of interest, or the value of the property in controversy",
amounts to not more than PHP10,000. Secondly, "the power to define, prescribe, and apportion the
jurisdiction of the various courts" belongs to Congress and is beyond the rule-making power of the
Supreme Court, which is limited to matters concerning pleading, practice, and procedure in all
courts, and the admission to the practice of law. Thirdly, the failure of said section 19 of Rule 5 of
the present Rules of Court to make its Rule 63, on interpleading, applicable to inferior courts, merely
implies that the same are not bound to follow Rule 63 in dealing with cases of interpleading, but may
apply thereto the general rules on procedure applicable to ordinary civil action in said courts.

You might also like