Case Digest (G.R. No. 197920)
Facts:
Demosthenes R. Arbilon v. Sofronio Manlangit, G.R. No. 197920, January 22, 2018, the Supreme Court First Division, Tijam, J., writing for the Court. Petitioner Arbilon (petitioner) seeks review of the Court of Appeals Decision dated January 14, 2011 in CA‑G.R. CV No. 00038, which reversed the Regional Trial Court of Davao City, Branch 33 (RTC) Decision of May 5, 2003 in Civil Case No. 27,498‑99 dismissing respondent Sofronio Manlangit’s (respondent) complaint for recovery of possession with writ of replevin and ordering return of an Atlas Copco compressor to petitioner.Respondent filed the complaint alleging he purchased on credit from Davao Diamond Industrial Supply one compressor for P200,000 (and other equipment), and that the compressor had been in petitioner’s possession from November 1997 until suit; petitioner allegedly refused to return it. Petitioner answered and counterclaimed, denying respondent’s ownership because respondent failed to pay the purchase price; petitioner contended he voluntarily assumed the obligation to pay Davao Diamond in installments because the compressor was indispensable to the mining operations of Double A.
Upon posting of bond, the RTC granted the writ of replevin and delivered the compressor to respondent. At trial, evidence showed a sales invoice bearing a reservation clause that goods remain seller’s property until fully paid; receipts and cash vouchers indicated that Lucia Sanchez Leanillo (Leanillo) paid installments in 1998 and that respondent later wrote Davao Diamond a letter dated August 5, 1999 purportedly surrendering the compressor and pump.
The RTC in its May 5, 2003 Decision found that respondent effectively surrendered his rights by his August 5, 1999 letter and that Leanillo’s payments evidenced that ownership had passed to her; it dismissed respondent’s complaint, dissolved the writ of seizure, declared respondent not entitled to possession, and ordered return of the compressor to petitioner and Leanillo (or, if not possible, payment of its value). On appeal, the Court of Appeals reversed on January 14, 2011, holding the transaction between respondent and Davao Diamond was a contract to sell (title reserved until full payment), that Leanillo’s payments benefited respondent and thus vested ownership in respondent, and that respondent need not reimburse Leanillo because evidence showed the payments came from respondent’s partnership share.
Petitioner filed a Rule 45 petition for review on certiorari before the Court, raising primarily wheth...(Subscriber-Only)
Issues:
- In an action for recovery of possession, may the Court decide the issue of ownership (limited to determining who has the better right to possess)?
- Did the Court of Appeals err in ruling that respondent is the owner of the compressor and therefore entitled to possession?
- Did the money used by Leanillo to pay for the compressor come from respondent’s partnership share, relieving respondent of an...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)