Case Digest (G.R. No. 3413)
Facts:
The case of Pomposa Bonjoc et al. vs. Candelario Cuison, G.R. No. 3413, was decided on March 27, 1909. The plaintiffs, Pomposa Bonjoc and others, filed a complaint against the defendant, Candelario Cuison, regarding the destruction of a house that originally belonged to the plaintiffs. The defendant admitted to destroying the house and taking possession of its materials. The crux of the dispute revolved around the ownership of the house at the time of its destruction. The defendant claimed that the house was assigned to him as security for a debt owed by the deceased husband of the plaintiff, which the plaintiff acknowledged after her husband's death in 1902. The defendant presented a document, marked as Exhibit 2, which he claimed was signed by the plaintiff to secure the debt. However, the document was in the Cebuano dialect and had not been translated into Spanish. The defendant and his witnesses testified that the document was a guarantee for the debt, while the plain...
Case Digest (G.R. No. 3413)
Facts:
- 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.
Overview of the Case
- 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.
The Destruction of the House
- 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.
Disputed Issue of Ownership
- 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.
Evidence Presented (Exhibit 2)
- 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.
Relief Sought by the Plaintiffs
- 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.
Lower Court’s Findings and Award
Issue:
- Whether, at the time the house was destroyed, it still belonged to the plaintiff or had been transferred to the defendant.
Ownership of the House
- 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.
Nature of the Contractual Arrangement
- Whether the defendant had the right to destroy the house, take possession of its materials, and dispose of them.
Lawfulness of the Defendant’s Actions
- 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.
Assessment of Damages
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)