Title
Baltazar vs. Layug
Case
G.R. No. 47646
Decision Date
Jun 10, 1941
Tenants intervened in a foreclosure case, claiming half of the sugar-cane crop they cultivated; Supreme Court upheld their ownership rights, invalidating the mortgage on their share.
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Case Digest (G.R. No. 47646)

Facts:

    Background and Initiation of Proceedings

    • Francisco Baltazar, in his capacity as judicial receiver of the Mabalacat Sugar Central, brought the action.
    • The Mabalacat Sugar Central was in receivership following a foreclosure proceeding instituted by Cu Unjieng and sons.

    Replevin Action and Seizure of the Sugar-Cane Crop

    • On February 9, 1932, Baltazar filed an action in the Court of First Instance of Pampanga against Geo. C. Sellner.
    • The suit sought the foreclosure of a chattel mortgage on the standing sugar-cane crop at the "Hacienda Concepcion" for the agricultural year 1931-1932.
    • A writ of replevin was issued, which led to the seizure of the sugar-cane crop, its milling at the Mabalacat Sugar Central, and its eventual sale.
    • The proceeds from the sale were applied by the receiver as partial payment of Geo. C. Sellner’s mortgage indebtedness.

    Intervention by the Respondents

    • On July 6, 1932, respondents, as tenants of the "Hacienda Concepcion," sought leave to intervene in the action.
    • The respondents petitioned for the liquidation of their shares in the sugar-cane crop and an order directing the receiver to pay them their respective shares.

    Appointment of the Commissioner and Court Proceedings

    • The trial court authorized the respondents’ intervention and approved their petition for liquidation, leading to the appointment of a commissioner.
    • On June 8, 1938, the commissioner submitted a report based on the gathered evidence.
    • The trial court approved the commissioner’s report, and a judgment was rendered ordering the Mabalacat Sugar Central and Geo. C. Sellner to pay the respondents specific amounts as determined by the report.
    • Concurrently, an order was issued fixing the commissioner’s fee at P250 and directing that it be split equally between the parties.

    Stipulations and Contention on the Nature of the Sugar-Cane Crop

    • An expressed stipulation by the parties stated that Geo. C. Sellner was the lessee of the "Hacienda Concepcion" and the respondents, as his tenants, were entitled to one-half of the proceeds of the crop each raised and harvested individually.
    • Appellants contested the allocation by arguing that distinguishing between the crop and its proceeds was immaterial, and that it did not affect the overall distribution of rights.

    Contentions Raised by the Appellants on the Receiver’s Rights

    • The appellants argued it was an error for the Court of Appeals to hold that one-half of the sugar-cane crop belonged to the respondents.
    • They contended that the receiver, as mortgagee, had no legal right to the portion of the crop that was, in fact, the respondents’ property.
    • The appellants also challenged the finding that the receiver had knowledge, at the time of executing the mortgage, of the respondents’ interest in half of the sugar-cane crop, although this was deemed a question of fact outside judicial review.
    • Finally, they argued against the trial court's permission for the respondents’ intervention, a stance weakened by Geo. C. Sellner’s acquiescence in open court.

Issue:

  • Whether it was erroneous for the Court of Appeals to determine that one-half of the sugar-cane crop at the "Hacienda Concepcion" belonged to the respondents.
  • Whether the execution of the foreclosure and replevin actions, particularly the levy on the sugar-cane crop to satisfy Sellner’s mortgage indebtedness, was lawful given the respondents’ entitlement.
  • Whether the receiver, in his capacity as mortgagee, had any right to dispose of or levy upon the half of the sugar-cane crop which legitimately belonged to the respondents.
  • Whether the intervention of the respondents was properly allowed under the applicable law, specifically under section 121 of Act No. 190.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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