Title
Koa vs. Court of Appeals
Case
G.R. No. 84847
Decision Date
Mar 5, 1993
A couple was relieved from their vehicle's remaining credit balance as the assignee took over the seller's obligations without a breach of warranty, leading to the dismissal of the replevin complaint.
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Case Digest (G.R. No. 84847)

Facts:

  • Petitioners: Henry L. Koa and Virginia Koa.
  • Respondents: Honorable Court of Appeals and BA Finance Corporation.
  • On April 20, 1977, the Koa spouses secured a credit of P26,422.20 from People’s Car, Inc. for a Volkswagen Trakbayan de Luxe.
  • The credit was backed by a promissory note with a 14% interest on unpaid installments, payable in monthly installments of P733.95 for 36 months, starting July 1, 1977.
  • A penalty of P10.00 was imposed for each month of unpaid installments.
  • The Koa spouses executed a chattel mortgage on the vehicle for compliance.
  • On May 27, 1977, People’s Car, Inc. assigned the promissory note and chattel mortgage to BA Finance Corporation.
  • The Koa spouses paid P14,679.00, leaving an unpaid balance of P12,236.98, plus interest and penalties.
  • BA Finance Corporation filed a complaint for "Replevin with Damages" due to over six months of non-payment.
  • The Koa spouses filed an Answer and a Third-Party Complaint against People’s Car, Inc.
  • The Regional Trial Court ruled in favor of BA Finance Corporation, ordering payment of the unpaid balance and dismissing the third-party complaint.
  • The Koa spouses appealed to the Court of Appeals, which affirmed the trial court's decision.
  • Their motion for reconsideration was denied, leading to a petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court found merit in the Koa spouses' argument that BA Finance Corporation was bound by the warranty obligations of People’s Car, Inc.
  • The Court ruled that the Koa spouses should be exonerated from paying the balance due to the principle against unjust enrichment....(Unlock)

Ratio:

  • The Supreme Court emphasized that when a seller assigns a credit to another party, the assignee inherits both the rights and obligations of the seller.
  • BA Finance Corporation, as the assignee, was bound by the same terms as the original agreement with People’s Car, Inc.
  • The Court cited...continue reading

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