Title
American Foreign Banking Corp. vs. Herridge
Case
G.R. No. 21005
Decision Date
Dec 20, 1924
A 1920 quedan for 560 bales of tobacco, endorsed to AFBC as security, was upheld as valid despite a discrepancy in origin (Cagayan vs. Isabela), affirming AFBC's superior title.

Case Digest (G.R. No. 87059)

Facts:

  • Issuance of Warehouse Receipt:
On April 28, 1920, U. de Poli, a licensed public warehouseman in Manila, issued warehouse receipt No. A-48 (quedan) for 560 bales of tobacco, described as "Cagayan tabaco en rama." He certified on the receipt that he was the sole owner of the merchandise.
  • Endorsement and Delivery:
The quedan was endorsed in blank by U. de Poli and delivered to the American Foreign Banking Corporation (AFBC) as security for an overdraft of approximately P40,000.
  • Claim by AFBC:
On April 23, 1921, AFBC filed a motion requesting the assignee of U. de Poli's insolvent estate to deliver the 560 bales of tobacco listed in the quedan.
  • Assignee's Defense:
The assignee, J. R. Herridge, denied possession of the 560 bales of Cagayan tobacco and contested the validity of the quedan as a negotiable warehouse receipt. He argued that the quedan did not comply with the Warehouse Receipt Act and was invalid as collateral for a preexisting debt.
  • Discrepancy in Description:
The quedan described the tobacco as "Cagayan," but the actual tobacco in the warehouse was "Isabela" tobacco. U. de Poli explained that he issued the quedan based on grade, not origin, and that the tobacco was intended as security regardless of its origin.
  • Evidence of Ownership:
    • de Poli testified that the tobacco was in the warehouse when he issued the quedan and that it was the same tobacco he transferred to AFBC. The assignee also pointed out the 530 bales of tobacco (the actual quantity) to AFBC's representative, confirming their identity.
  • Precedent Case:
The quedan was similar to one in the case of *Felisa Roman vs. Asia Banking Corporation*, where the Supreme Court ruled that such a quedan was a negotiable warehouse receipt conveying superior title to the bank.

Issues:

  • Whether the quedan (Exhibit A) is a valid negotiable warehouse receipt under the Warehouse Receipt Act.
  • Whether the discrepancy in the description of the tobacco (Cagayan vs. Isabela) renders the quedan null and void.
  • Whether AFBC is entitled to the 530 bales of tobacco as the rightful owner or lienholder.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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