Case Digest (G.R. No. L-36249)
Case Digest (G.R. No. L-36249)
Facts:
Aniano Obana v. The Court of Appeals and Aniceto Sandoval, G.R. No. L-36249, March 29, 1985, First Division, Melencio-Herrera, J., writing for the Court.
Aniceto Sandoval (private respondent) owned and managed the Sandoval and Sons Rice Mill and dealt in palay. On November 21, 1964, a certain Chan Lin agreed with Sandoval to buy 170 cavans of cleaned rice (wagwag variety) at P37.25 per cavan, with delivery the next day at petitioner Aniano Obana’s store in San Fernando, La Union, and payment to be made there to Sandoval’s representative. Sandoval accepted because he knew Obana and had transacted with him previously.
On November 22 the rice was transported on Sandoval’s truck to Obana’s store; Chan Lin accompanied the shipment. When Sandoval’s driver attempted to collect the purchase price from Chan Lin, the latter was absent; Obana refused to pay, claiming he had in fact bought the rice from Chan Lin at P33.00 per cavan and that he had already paid Chan Lin. Sandoval then filed an action for replevin against Obana in the Municipal Court of San Fernando, La Union. The Municipal Court ordered Obana to pay one-half of the cost of the rice (P2,805.00).
Obana appealed to the Court of First Instance (then) of La Union where the parties agreed to adopt Sandoval’s Municipal Court testimony; after trial de novo the Court of First Instance dismissed Sandoval’s complaint. Sandoval appealed to the Court of Appeals, which reversed and ordered Obana to return the 170 cavans or pay their value at P37.25 per cavan, with legal interest from filing until paid. Petitioner Obana sought review in the Supreme Court; he challenged the Appellate Court’s findings that Chan Lin had not intended to comply with Sandoval and that, in equity, Sandoval as undisputed owner should recover the rice or its value.
During trial the record showed conflicting testimony: Obana admitted that three days after delivery Chan Lin and Sandoval’s driver returned, gave him P5,600 and he allegedly delivered the rice back to them; the driver denied any return. The Court found the driver’s denial more credible and examined whether title had vested and whether any rescission occurred.
Issues:
- Was there a perfected sale of the 170 cavans of rice to Chan Lin, and did ownership pass to him upon delivery?
- Is Aniceto Sandoval entitled to recover the rice (or its value) from Aniano Obana despite Obana’s claim he bought the rice from Chan Lin and received payment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)