Title
Bonjoc vs. Cuison
Case
G.R. No. 3413
Decision Date
Mar 27, 1909
Defendant destroyed plaintiffs' house, claiming ownership via a disputed debt guarantee document. Court ruled house remained plaintiffs' property, awarding ₱500 compensation and ₱150 damages for unlawful destruction.
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Case Digest (G.R. No. 3413)

Facts:

    Overview of the Case

    • Plaintiffs: Pompiosa Bonjoc et al.
    • Defendant: Candelario Cuison.
    • The case arises from the destruction of a house and the subsequent taking of its materials by the defendant.

    The Destruction of the House

    • It was fully proven through the testimony of the plaintiffs’ witnesses—and partially admitted by the defendant—that the defendant destroyed (or ordered the destruction of) a house.
    • The defendant took possession of the house’s materials and retained them until the present time.

    Disputed Issue of Ownership

    • The central question is whether, at the time of its destruction, the house belonged to the plaintiff or to the defendant.
    • The defendant acknowledges that originally the house belonged to the plaintiff.
    • The defendant contends that after the death of the plaintiff’s husband, a debt existed for which the plaintiff, in 1902, assigned the house as security.

    Evidence Presented (Exhibit 2)

    • The defendant introduced a document marked “Exhibit 2” as evidence.
    • The document is written in the Cebuano dialect and was not translated into Spanish.
    • It was signed by a witness (at the plaintiff’s request) and two other witnesses present at its execution.
    • Testimonies Explained the Document’s Contents:
    • The defendant testified that the document was executed by the plaintiff to give the house as security—stating phrases such as “She executed a document by which she gave the house as security” and “This is the document that she handed me giving me the house as security.”
    • Two witnesses corroborated that the house was given merely as a guaranty for a debt, not as a transfer of ownership.
    • Discrepancies in the Evidence:
    • Contradictory testimonies emerged regarding the creation of Exhibit 2: the defendant claimed it was written by Esteban Gonzalez while his witnesses asserted it was authored by Claudio Ralota.
    • Other significant contradictions in the declarations of the defendant and his witnesses rendered their overall testimony suspicious.

    Relief Sought by the Plaintiffs

    • The complaint requested a judgment for:
    • Possession of the house’s materials that were unlawfully retained by the defendant, or alternatively,
    • Payment of the sum of 500 pesos in case the materials were irretrievable.
    • In addition, the plaintiffs made a general request for any other equitable remedy available under Section 90 of the Code of Civil Procedure.

    Lower Court’s Findings and Award

    • The lower court sentenced the defendant to pay 500 pesos.
    • It was determined, based on evidence, that the destroyed house was actually worth 500 pesos.
    • Recognizing that the plaintiffs were unjustly deprived of the use of the house and incurred losses, the court also assessed an additional 150 pesos in damages for such losses.
    • Although the defendant argued that the verdict on losses and damages should account only for legal interest on the net assessed amount, this contention was ultimately dismissed.

Issue:

    Ownership of the House

    • Whether, at the time the house was destroyed, it still belonged to the plaintiff or had been transferred to the defendant.

    Nature of the Contractual Arrangement

    • Whether the document (Exhibit 2), executed as a security for a debt, effectively transferred the title of ownership to the defendant.
    • Whether a contract of guaranty may give rise to an act of dominion such as the destruction of the property.

    Lawfulness of the Defendant’s Actions

    • Whether the defendant had the right to destroy the house, take possession of its materials, and dispose of them.

    Assessment of Damages

    • Whether the lower court erred in awarding 500 pesos based on the value of the house and an additional 150 pesos for losses arising from unjust deprivation of use.
    • Whether the computation of legal interest should have been altered given the nature of the indemnity claim.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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