Title
Jao vs. Royal Ficing Corp.
Case
G.R. No. L-16716
Decision Date
Apr 28, 1962
The court ruled that a surety bond cannot be executed for a mortgage claim without proper application and substantiated damages.
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Case Digest (G.R. No. L-16716)

Facts:

  • On October 30, 1957, spouses Pedro R. Jao and Catalina Sia executed a promissory note in favor of Royal Financing Corporation, secured by a chattel mortgage dated October 31, 1957.
  • Following a default, the defendant initiated an extra-judicial foreclosure, announcing a public auction for July 11, 1958.
  • On July 7, 1958, the plaintiffs filed a complaint against the defendant and the Sheriff, seeking to declare the promissory note and chattel mortgage null and void, claiming they had settled the obligation.
  • The plaintiffs sought to prevent the sale of their properties and demanded damages, including attorney's fees.
  • To halt the auction, the plaintiffs posted a bond for preliminary injunction amounting to P2,500.00, with Associated Insurance & Surety Co., Inc. as the surety.
  • The trial court granted the injunction, suspending the sale.
  • The defendants counterclaimed for damages, asserting that the plaintiffs were still indebted.
  • On June 11, 1959, the trial court dismissed the case due to the plaintiffs' failure to appear at a scheduled hearing.
  • Following dismissal, the defendant corporation moved for judgment against the surety bond, claiming the mortgaged properties were no longer in the plaintiffs' possession.
  • The surety company opposed, arguing the motion was premature since the counterclaim was unresolved.
  • The trial court ruled in favor of the defendant, ordering execution of the bond to satisfy its mortgage claim.
  • The surety company appealed, raising legal questions regarding the bond's nature and the judgment's execution.

Issue:

  • (Unlock)

Ruling:

  • Yes, the trial court erred in holding that the bond was intended to secure the defendant corporation's mortgage credit.
  • No, the trial court was incor...(Unlock)

Ratio:

  • The Supreme Court clarified that the bond was intended to secure the defendant's right to damages from the preliminary injunction, not to secure mortgage credit.
  • The bond's language explicitly stated it was to cover damages if the plaintiffs were found not entitled to the injunction.
  • A guaranty cannot ...continue reading

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