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JurisprudenceG.R. No. 214074

PHILIPPINE NATIONAL BANK,�, VS. MEDIAN CONTAINER CORPORATION AND ELDON INDUSTRIAL CORPORATION,�.

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Decision

Ruling

Accordingly, since it did not acquire jurisdiction over PNB's counterclaim, the motion to implead is improper. 12 Dissatisfied with the RTC's ruling, PNB sought reconsideration but was denied in a Resolution 13 dated July 29, 2011. Determined, it elevated the case before the CAviaPetition for Certiorari . The CA Ruling In a Decision 14 dated March 19, 2014, the CA dismissed PNB's certiorari petition for lack of merit. The CA held that PNB's counterclaim for the recovery of the amount representing the proceeds of the sale of the goods covered by the trust receipts or the amount of goods which respondents failed to turn over is permissive. According to the CA, the evidence required to determine the real agreement of the parties, i.e. , contract of loan or some other agreement, is different from that evidence needed to establish PNB's claim for unpaid obligations due to respondents' failure and/or refusal to turn over the proceeds of the sale of the goods covered by the trust receipts. 15 Additionally, the CA highlighted that the issue in respondents' complaint, i.e. , whether the trust receipts reflect the parties' real agreement, is different from the issue in the counterclaim, which is whether respondents are liable to pay the amount claimed by PNB. 16 Since PNB's counterclaim is permissive, the CA ruled that the former was bound to pay the prescribed docket fees for the RTC to acquire jurisdiction, failing in which, the counterclaim shall be dismissed for nonpayment of docket fees as in this case. At any rate, the CA stressed that PNB is not without recourse as it can still file a separate action against respondents. Consequently, the CA declared that the RTC did not commit grave abuse of discretion in dismissing PNB's counterclaim and denying its motion to implead Spouses Ley. 17 Aggrieved, PNB moved for reconsideration but was denied in a Resolution 18 dated August 18, 2014. Hence, it filed the present Petition. The Issue before the Court The issue before the Court is whether the CA committed reversible error in upholding the RTC's ruling that dismissed PNB's counterclaim and motion to implead Spouses Ley. PNB maintains that its counterclaim, with motion to implead Spouses Ley, for the payment of the amount of PHP 31,059,616.29 representing respondents' obligation under the trust receipts is necessarily connected with and logically related to the latter's petition for reformation of said instruments since they require the same set of evidence and raise essentially the same issues. 19 At any rate, PNB argues that the RTC should not have dismissed its counterclaim outright, asserting that the RTC should have instead directed it to pay the required docket fees. 20 Moreover, PNB insists that Spouses Ley are real parties-in-interest in its counterclaim who must therefore be impleaded in the case for a complete determination of the same. In this regard, it points out that Spouses Ley agreed to be jointly and severally liable with respondent