Title
American Express Co., Inc. vs. Natividad
Case
G.R. No. 22073
Decision Date
Sep 25, 1924
Customs collector Joaquin Natividad delivered goods without bills of lading, leading to a lawsuit by American Express Co. Supreme Court ruled Natividad personally liable for wrongful delivery, affirming plaintiff's standing as bill holder.
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Case Digest (G.R. No. 22073)

Facts:

  1. Shipment and Delivery of Merchandise:

    • During late 1920 and early 1921, shipments of merchandise from Japan were discharged at Cebu, Philippines.
    • Joaquin Natividad was the collector of customs at Cebu during this period.
    • The merchandise was delivered to Chua Cho Pack & Co. without the presentation of bills of lading, after the execution of bonds in favor of the Government of the Philippine Islands.
  2. Demand for Merchandise:

    • The American Express Co., Inc. (plaintiff) later presented the bills of lading and demanded the merchandise or its value.
    • Since Natividad had already delivered the goods to another party, he could not comply with this demand.
  3. Legal Action:

    • The American Express Co., Inc. filed a lawsuit in the Court of First Instance of Manila, seeking to recover P55,102.18 (later reduced to P43,131.78) from Joaquin Natividad.
    • The defendant, Natividad, argued that he was not a proper party defendant as a private individual and that the merchandise was delivered upon the execution of bonds.
  4. Trial Court Decision:

    • The trial court ruled in favor of the plaintiff but held the "Administrador de Aduanas de Cebu" (Customs Administrator of Cebu) liable instead of Natividad personally.
  5. Appeals:

    • Both parties appealed the decision.
    • The plaintiff argued that Natividad should be held personally liable.
    • The defendant argued that the plaintiff was not the real party in interest.

Issue:

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Ruling:

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Ratio:

  1. Real Party in Interest:

    • The holder of the bills of lading, with proper indorsements and legal title, is the real party in interest entitled to maintain an action for the recovery of merchandise or its value.
  2. Personal Liability of Customs Officials:

    • A collector of customs is personally liable for the wrongful delivery of merchandise without the surrender of the proper bills of lading.
    • The execution of indemnity bonds does not diminish this personal liability. The bonds are for the collector's protection, not for the rightful holder of the bills of lading.
  3. Pleadings and Objections:

    • Objections regarding the plaintiff's standing as the real party in interest must be raised in the lower court; otherwise, they cannot be relied upon on appeal.


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