Title
Mariano vs. Court of Appeals
Case
G.R. No. 51283
Decision Date
Jun 7, 1989
Esther Sanchez sued Lourdes Mariano for unpaid dresses; attachment was improperly issued. Conjugal assets were liable as Esther's business benefited the family; Quezon City Court improperly interfered in Caloocan Court’s execution process.
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Case Digest (G.R. No. 51283)

Facts:

  1. Origins of the Case: The case originated from a suit filed by Esther Sanchez against Lourdes Mariano in the Court of First Instance at Caloocan City for the recovery of the value of ladies' ready-made dresses allegedly purchased and delivered to Lourdes Mariano. A writ of preliminary attachment was issued, leading to the seizure of Lourdes Mariano's property worth approximately P15,000.00.

  2. Attachment and Trial: Lourdes Mariano's motion to discharge the attachment was denied, prompting her to file a petition for certiorari with the Court of Appeals. The Trial Court later dissolved the attachment, finding it improperly issued. The case proceeded to trial, resulting in a judgment in favor of Lourdes Mariano, who was awarded damages and attorney's fees.

  3. Execution of Judgment: Esther Sanchez attempted to appeal the judgment, but Lourdes Mariano moved for immediate execution, which was granted. The sheriff garnished funds from Veritas Insurance Company and levied on conjugal property belonging to Esther Sanchez and her husband, Daniel Sanchez.

  4. Interference by Daniel Sanchez: Daniel Sanchez, Esther's husband, filed a separate action in the Court of First Instance at Quezon City to annul the execution, claiming that the conjugal assets could not be used to satisfy his wife's obligations. He also sought a preliminary injunction to halt the auction sale of the levied property.

  5. Appellate Proceedings: Lourdes Mariano filed a special civil action of certiorari in the Court of Appeals, which initially restrained the Quezon City Court but was later dismissed by the Eighth Division. Lourdes Mariano appealed to the Supreme Court, raising issues regarding the liability of the conjugal partnership and the alleged interference by the Quezon City Court.

Issue:

  1. Whether the conjugal partnership of Daniel and Esther Sanchez could be held liable for Esther's judgment obligation arising from her business, which benefited the family.
  2. Whether the Quezon City Court of First Instance improperly interfered with the execution process of the Caloocan Court of First Instance.
  3. Whether the Eighth Division of the Court of Appeals improperly took cognizance of the case after it had been raffled to the Seventh Division.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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