G.R. No. 35223 - Bachrach Motor Co., Inc. vs. Talisay-Silay Milling Co.

The Bachrach Motor Co., Inc. (plaintiff-appellee) sought delivery of ₱13,850 in promissory notes or other credit instruments purportedly due as bonus in favor of planter Mariano Lacson Ledesma.
The Talisay-Silay Milling Co., Inc. (defendant-appellee) was sued for accounting and payment of all amounts owed to Ledesma, and for annulment of a sale made by Ledesma.

The Philippine National Bank (intervenor-appellant) claimed a preferential right over any bonus due to Ledesma, asserting such bonus were civil fruits of land mortgaged to the bank.
The bank sought direct payment of the bonus to satisfy Ledesma’s debt to it by virtue of a mortgage and deed of assignment (Exhibit 9).

Talisay-Silay Milling argued that ₱7,500 of Ledesma’s claimed bonus belonged to Cesar Ledesma, a bona fide purchaser, and requested relief accordingly.
Cesar Ledesma filed an answer asserting title to the ₱7,500 share, seeking dismissal of claims against him.
Bachrach Motor answered the bank’s intervention, asserting its credit against Ledesma was prior and preferred, and prayed for dismissal of the bank’s claim.

All parties agreed to respect the sale to Cesar Ledesma; the trial court dismissed claims against him and ordered payment of ₱7,500 to Cesar.
After hearing, the trial court held that Bachrach Motor’s attachment and credit (₱11,076.02) against Ledesma’s bonus had priority over the bank’s claim, and ordered Talisay-Silay Milling to pay said sum to Bachrach Motor.

Failure to treat the bonus as civil fruits of mortgaged land.
Failure to treat bonus as subject to Ledesma’s mortgage when due.
Finding the assignment (Exhibit 9) fraudulent or void.
Upholding Bachrach Motor’s attachments and admissions of supplementary pleadings.
Denying the bank’s preferential right to the bonus.

Whether the bonus granted by Talisay-Silay Milling Co., Inc. constitutes “civil fruits” of Ledesma’s mortgaged land under Article 355 of the Civil Code.
Whether the bonus fell due and became subject to the mortgage executed by Ledesma in favor of the Philippine National Bank.
Whether the assignment of the bonus (Exhibit 9) by Ledesma to the bank is void for erroneous consideration or fraudulent.
Whether Bachrach Motor’s attachments on the bonus in two separate suits were valid and gave it a prior preferential right.
Whether the trial court properly admitted and considered Bachrach Motor’s supplementary pleadings.
Whether the Philippine National Bank has a superior right to the bonus over Bachrach Motor.