Case Digest (G.R. No. 232814)
Facts:
In Police Sr. Sup’t. Romeo Uy, et al. v. Sergio Jr. and Sales V. Jacalan, respondents Sergio Jr. and Sales V. Jacalan purchased a secondhand Isuzu Wagon (Chassis No. PABT BR54F32015320; Engine No. BD9614; Plate No. LMD-295) from Ryan Gallego through Oro Cars in Bulua, Cagayan de Oro City, paying ₱75,000.00. A PNP Motor Vehicle Clearance Certificate dated August 29, 2006 and a Macro-Etching Certificate declared the engine and chassis numbers “not tampered” and not listed as stolen. On March 7, 2008, respondents’ driver was stopped by SPO1 Felmandie Tatlonghari, SPO1 Michael Aycardo, SPO1 Gerry Gentallan, and SPO1 Rommel Flores for a seat belt violation and suspicion of spurious OR/CR. The subject vehicle was impounded on March 14, 2008, and later transported to Camp Crame, Quezon City for further examination upon the verbal instruction of PS/Supt. Uy. Respondents filed a complaint for replevin in the Regional Trial Court (RTC), Misamis Oriental, Cagayan de Oro City (Civil Case NoCase Digest (G.R. No. 232814)
Facts:
- Factual Background
- Respondents Sergio Jr. and Sales V. Jacalan acquired a second-hand Isuzu Wagon (Chassis No. PABTBR54F32015320; Engine No. BD9614; Plate No. LMD-295) from Ryan Gallego via Oro Cars, Bulua, Cagayan de Oro City, for ₱75,000.00.
- The PNP-Traffic Management Group issued a Motor Vehicle Clearance Certificate (MVCC) dated August 29, 2006, certifying the vehicle “not in the list of wanted/stolen vehicles,” and a Macro-Etching Certificate indicating no tampering of chassis/engine numbers.
- Impounding of the Vehicle
- On March 7, 2008, respondents’ driver was stopped by petitioning officers for a seat‐belt violation; the officers suspected the vehicle’s OR and CR were spurious and impounded it under an Impounding Receipt dated March 14, 2008.
- Petitioners refused respondents’ demand for release, alleging chassis/engine tampering and claiming custodia legis under the Anti-Carnapping Act; they transported the vehicle to Camp Crame for further examination.
- Procedural History
- Respondents filed a replevin complaint in the RTC, seeking return of the vehicle or payment of its actual value plus interest, damages, attorney’s fees, litigation expenses, and costs.
- The RTC ruled in respondents’ favor (June 30, 2014), ordering defendants to pay the vehicle’s actual value (₱475,000.00) with interest, moral damages, attorney’s fees, litigation expenses, and costs. The CA affirmed (April 6, 2017; Resolution July 5, 2017). Petitioners filed a Rule 45 petition before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in directing petitioners to pay respondents the actual value of the seized vehicle.
- Whether the Court of Appeals erred in awarding moral damages to respondents.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)