Metropolitan Bank & Trust Company vs. Absolute Management Corporation

A fourth-party complaint against a decedent's estate asserting a contingent claim for reimbursement based on quasi-contract must be filed as a money claim in the special proceeding for the settlement of the estate under Section 5, Rule 86 of the Rules of Court, rather than as an impleader in an ordinary civil action under Section 11, Rule 6.

Sherwood Holdings Corporation, Inc. (SHCI) filed a complaint for sum of money against Absolute Management Corporation (AMC) for undelivered plywood and plyboards paid for via crossed Metrobank checks payable to AMC. AMC's General Manager, Jose L. Chua, received the checks in 1998 but died in 1999; his estate was undergoing judicial settlement in Pasay City. AMC denied receiving the proceeds and filed a third-party complaint against Metrobank, which had deposited the checks into the account of Ayala Lumber and Hardware, a sole proprietorship owned by Chua.

• The Underlying Transaction: SHCI made advance payments to AMC for plywood and plyboards using crossed Metrobank checks payable to AMC. Chua, AMC's General Manager, received the checks in 1998.
• The Third-Party Complaint: AMC denied receiving the proceeds and filed a third-party complaint against Metrobank. Metrobank admitted depositing the checks into the account of Ayala Lumber and Hardware, a sole proprietorship owned by Chua, based on Chua's assurances and authority. Metrobank claimed AMC was estopped from questioning Chua's authority and was guilty of gross negligence for giving Chua unbridled control.
• The Fourth-Party Complaint: Metrobank sought to file a fourth-party complaint against Chua's estate, alleging that the estate should reimburse Metrobank if it were held liable to AMC.
• Lower Court Denials: The RTC denied the motion to admit the fourth-party complaint, categorizing the claim as cobro de lo indebido—a quasi-contract that must be filed in the pending special proceeding for the settlement of Chua's estate under Section 5, Rule 86. The CA affirmed the RTC, ruling that the specific provisions of Section 5, Rule 86 prevail over the general provisions of Section 11, Rule 6.

• Rule 45 Compliance: Petitioner argued that the omission of adverse party pleadings in the petition was not fatal and did not warrant outright dismissal, as the arguments were discernible from the court orders and the missing documents were later attached in the Reply.
• Impleader Under Rule 6: Petitioner maintained that Section 11, Rule 6 of the Rules of Court should apply, allowing the fourth-party complaint against Chua's estate for reimbursement in the same transaction for which it was sued by AMC.

• Rule 45 Violation: Respondent countered that the petition should be dismissed outright for violating Section 4, Rule 45 of the Rules of Court due to the failure to append relevant pleadings from the adverse party.
• Money Claim Against Estate: Respondent argued that Metrobank's claim is a quasi-contract constituting a money claim against a deceased person, which must be filed in the special proceeding under Section 5, Rule 86 of the Rules of Court.

• Procedural Compliance: Whether the petition for review on certiorari complies with Section 4, Rule 45 of the Rules of Court despite the omission of some adverse party pleadings.
• Proper Venue for Claim: Whether Metrobank's fourth-party complaint against Chua's estate should be allowed in the ordinary civil action or filed as a money claim in the special proceeding under Section 5, Rule 86 of the Rules of Court.

• Procedural Compliance: The petition was found to substantially comply with Section 4, Rule 45. The requirement is not an absolute rule mandating automatic dismissal; procedural rules are liberally construed to promote just, speedy, and inexpensive determinations. The omitted pleadings were eventually submitted, and the core issues were clear from the lower court orders.
• Proper Venue for Claim: The fourth-party complaint was correctly denied. Metrobank's claim is based on quasi-contract (solutio indebiti) and is contingent, falling under Section 5, Rule 86. Under the principle of lex specialis derogat generali, the specific provisions on special proceedings (Rule 86) prevail over general provisions on impleader in ordinary actions (Rule 6).

• Quasi-contracts as implied contracts under Rule 86 — Liabilities of the deceased arising from quasi-contracts are included in the term "implied contracts" under Section 5, Rule 86 and must be filed as claims in the settlement of the estate. The term "implied contracts" in remedial law originated from common law, where obligations derived from quasi-contracts and from law are both considered implied contracts.
• Contingent claims against a decedent — Contingent money claims against a decedent—claims that depend on a future event that may or may not happen—must be filed in the special proceeding for the settlement of the estate under Section 5, Rule 86.
• Lex specialis derogat generali in procedural rules — Specific provisions governing special proceedings (Rule 86) prevail over general provisions governing ordinary civil actions (Rule 6). Rules for ordinary actions apply only suppletorily to special proceedings.

• "The term quasi-contract is included in the concept 'implied contracts' as used in the Rules of Court. Accordingly, liabilities of the deceased arising from quasi-contracts should be filed as claims in the settlement of his estate, as provided in Section 5, Rule 86 of the Rules of Court."
• "A distinctive character of Metrobank’s fourth-party complaint is its contingent nature – the claim depends on the possibility that Metrobank would be adjudged liable to AMC, a future event that may or may not happen. This characteristic unmistakably marks the complaint as a contingent one that must be included in the claims falling under the terms of Section 5, Rule 86 of the Rules of Court."

• F.A.T. Kee Computer Systems, Inc. v. Online Networks International, Inc. — Followed. The failure to attach the transcript of stenographic notes or adverse party pleadings under Section 4, Rule 45 is not fatal; procedural rules are to be liberally construed, and the Court may require the elevation of the complete record if the petition is given due course.
• Maclan v. Garcia — Followed. A claim for necessary expenses spent as a previous possessor of land is a quasi-contract and falls under "implied contracts" that must be filed in the settlement of the decedent's estate under Section 5, Rule 86.
• Leung Ben v. O’Brien — Cited. Established that the term "implied contracts" in remedial law originated from common law, encompassing obligations derived from quasi-contracts.

• Section 5, Rule 86, Rules of Court — Applied as the specific provision governing money claims against a decedent's estate. All claims for money against the decedent, arising from contract express or implied, whether due, not due, or contingent, must be filed in the estate proceeding.
• Section 11, Rule 6, Rules of Court — Applied suppletorily; the general rule on third- and fourth-party complaints yields to the special rule on estate claims.
• Section 4, Rule 45, Rules of Court — Applied regarding the required contents of a petition for review; non-compliance did not warrant dismissal under the circumstances.
• Article 2154, Civil Code — Applied to characterize Metrobank's claim as solutio indebiti, a form of quasi-contract. The requisites are: (1) something was unduly delivered through mistake, and (2) something was received when there was no right to demand it.

Carpio (Chairperson), Del Castillo, Perez, Perlas-Bernabe