Case Digest (G.R. No. 48560)
Facts:
The case involves Binalbagan Estate, Inc. as the plaintiff and Valeriano M. Gatuslao and A. P. Seva as the defendants. The dispute arose from the sale of Hacienda San Jose, also known as lot No. 2075-A of the Himamaylan cadastre, which was sold by the sheriff on October 14, 1938, to Valeriano M. Gatuslao for P73,715.19. This sale was conducted to satisfy a mortgage against the estate of Rafael Jocson, deceased, in favor of the mortgagee, Segundo Monteblanco. The sale was confirmed by the court on December 9, 1938. The mortgage credit amounted to P100,989.21, of which P44,182.67 was awarded to Attorney A. P. Seva as his fees for services rendered in the foreclosure suit. However, only P4,266 from the sale proceeds was allocated to Seva's judgment.
At the time of the sale, the hacienda had a standing crop of sugar cane, which belonged to the lessees. The rents from this crop, payable in sugar, were determined to total 1,251 piculs and became due after the milling commenc...
Case Digest (G.R. No. 48560)
Facts:
Property and Mortgage Background:
- The case involves Hacienda San Jose, also known as Lot No. 2075-A of the Himamaylan (Occidental Negros) cadastre.
- The property was mortgaged by the Estate of Rafael Jocson to Segundo Monteblanco.
- The mortgage was foreclosed, and the property was sold by the sheriff on October 14, 1938, to Valeriano M. Gatuslao for P73,715.19 to satisfy the mortgage debt.
Rents and Pending Fruits:
- At the time of the sale, the hacienda had a standing crop of sugar cane belonging to lessees.
- The lessees were obligated to pay a portion of the sugar produced as rent to the owner of the hacienda.
- The rent amounted to 1,251 piculs of sugar, which became due after the milling of the sugar cane, which began shortly after October 14, 1938.
Conflicting Claims:
- Valeriano M. Gatuslao, as the purchaser of the hacienda, claimed the 1,251 piculs of sugar as part of the property he acquired.
- A. P. Seva, a mortgage creditor, also claimed the sugar as part of the mortgage credit.
- Binalbagan Estate, Inc., filed an interpleader action to resolve the conflicting claims.
Procedural History:
- The trial court authorized the sale of the sugar, and the proceeds (P8,376.20) were delivered to A. P. Seva, who posted a supersedeas bond.
- The trial court ruled in favor of Seva, citing Article 1877 of the Civil Code and the case of Afable vs. Belando.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Application of Article 1468 of the Civil Code:
- Article 1468 states that the vendor must deliver the thing sold in its condition at the time the contract was perfected, and all fruits shall belong to the vendee from that day.
- Since the sale of the hacienda to Gatuslao was perfected on October 14, 1938, the pending fruits (sugar) belonged to him from that date.
Effect of Sheriff's Sale:
- Under Section 257 of Act No. 190, the sale of mortgaged property by the sheriff divests the rights of all parties to the action and vests them in the purchaser.
- Seva, as a mortgage creditor, could not claim any rights to the property or its fruits after the sale.
Distinction from Afable vs. Belando:
- The Afable case involved a dispute between a mortgagee and an unsecured creditor over rents collected during the pendency of a foreclosure suit.
- In this case, the dispute was between the purchaser of the mortgaged property and the mortgage creditor, making Afable inapplicable.
Principle of Accessory Following the Principal:
- The pending fruits were considered accessories to the principal property (hacienda) and followed the ownership of the principal.
- Since Gatuslao became the owner of the hacienda, he also became the owner of the pending fruits.
The Supreme Court ordered A. P. Seva to pay Gatuslao the sum of P8,376.20 with interest at 6% per annum from December 4, 1939, and to bear the costs of the appeal.