Case Digest (G.R. No. 20329) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The Standard Oil Company of New York vs. Joaquin Jaramillo, G.R. No. 20329, decided March 16, 1923, the petitioner, a foreign corporation engaged in the oil business, alleges that on November 27, 1922, Gervasia de la Rosa, Vda. de Vera, as lessee of a parcel of land in the City of Manila, executed a document styled as a chattel mortgage in favor of the petitioner. The instrument purported to mortgage both her leasehold interest and the building of strong materials on the leased lot. After acknowledgment and delivery, the petitioner presented the document to the respondent, Joaquin Jaramillo, Register of Deeds of the City of Manila, for recordation under the Chattel Mortgage Law (Act No. 1508, as amended by Act No. 2496) and its successor provisions in section 198 of the Administrative Code. The register refused to record, contending the mortgaged interests were not “personal property” within the meaning of the law. The petitioner then filed an original petition for a perempto Case Digest (G.R. No. 20329) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Instrument
- Petitioner: The Standard Oil Company of New York; Respondent: Joaquin Jaramillo, Register of Deeds of the City of Manila.
- On November 27, 1922, Gervasia de la Rosa, Vda. de Vera (lessee and owner of a house on a leased lot in Manila) executed a document in the form of a chattel mortgage conveying by way of mortgage:
- Her leasehold interest in the lot.
- The building situated thereon.
- Registration Proceeding
- The instrument was duly acknowledged, delivered, and presented with the proper fee to the Register of Deeds for entry in the chattel mortgage registry.
- The Register refused to record it, opining that the interests mortgaged were not “personal property” under the Chattel Mortgage Law.
- Procedural Posture
- The Standard Oil Company filed an original petition for a peremptory mandamus in the Supreme Court to compel recording.
- The Register interposed a demurrer, challenging the petition’s sufficiency and asserting his discretion to refuse registration.
Issues:
- Does the Register of Deeds have authority to determine, before recording, whether the property described in a purported chattel mortgage is “personal property” under the Chattel Mortgage Law?
- Are the leasehold interest and the building described in the instrument personal property qualifying for registration as a chattel mortgage?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)