G.R. No. 169596 - Superlines Transportation Co., Inc. vs. Philippine National Construction Co.

Superlines Transportation Company, Inc. (petitioner) is a corporation engaged in public transportation.
On December 13, 1990, a Superlines bus, while traveling north and approaching the Alabang northbound exit lane, swerved and collided with the radio room of Philippine National Construction Company (PNCC), a respondent.
The bus, a Fuso (later replaced with a Nissan engine) with specific identifying details (Motor Number, Chassis Number, etc.), became the subject of subsequent dispute.

The incident was first investigated by PNCC’s tollway patrol, headed by Sofronio Salvanera, and Pedro Balubal, head of PNCC’s traffic control and security department.
The bus was then turned over to the Alabang Traffic Bureau for its own investigation.
Due to the lack of storage space, traffic investigator Pat. Cesar Lopera requested that the bus be towed and kept at the PNCC compound for safekeeping.

Petitioner repeatedly requested the release of the bus and offered to repair the damaged radio room.
Respondent Balubal denied the release, instead demanding a collateral of P40,000.00, representing PNCC’s estimate for reconstructing the radio room, though petitioner’s own estimate was only P10,000.00.

Petitioner filed a complaint for recovery of personal property (replevin) with damages against respondents PNCC and Pedro Balubal at the Regional Trial Court of Gumaca, Quezon.
The prayer in the complaint included:

Awarding petitioner material possession of the bus as its sole owner.
Monetary claims for unrealized income, attorney’s fees, litis expenses, and costs of suit.

Due to its inability to post the bond required for an immediate issuance of a writ of replevin, petitioner opted to await the final judgment.
Respondents contended that:

They had merely towed the bus for safekeeping following an order by the police authorities.
Balubal acted on instructions that required an order from the police before releasing the bus.
Petitioner failed to produce proper documentation (certificate of registration and receipt) to establish ownership.
The bus in question was not the same as the bus involved in the December 13, 1990 accident.

The trial court rendered a decision dismissing petitioner's complaint and ordering petitioner to pay respondent PNCC actual damages to the radio room.
On appeal to the Court of Appeals, the storage of the bus was deemed akin to a deposit, with custody remaining with the police investigator (Lopera).
The appellate court held that the proper action should have been against the police authorities, not against respondents PNCC and Balubal, leading to the present petition for review.
Respondents raised procedural objections regarding the petition’s compliance with Rule 45, Section 4 (contents and inclusion of supporting record portions), arguing that it should be dismissed.

The central issue involves whether the owner of personal property (the bus) may initiate a replevin action against a depositary and recover damages for illegal distraint.
The case also explored whether the seizure and impounding of the bus without proper court process or warrant violated the constitutional right against unreasonable searches and seizures as enshrined in Section 2, Article III of the Constitution.

Whether an owner may recover possession of personal property wrongfully detained by a depositary under replevin, even when the detention is based on a contract of deposit derived from a police order.
Whether the replevin remedy extends to recovery of the property when its seizure is conducted outside the bounds of a legal court order or proper process.

Whether the petition for review, despite alleged procedural defects in complying with Section 4, Rule 45 of the Rules of Court (i.e., failure to include all material portions of the record), should be dismissed or resolved on its merits under the Court’s equity jurisdiction.
Whether the failure to implead indispensable parties (such as the police authorities and, specifically, investigator Lopera) precludes petitioner from pursuing its claim for damages.

Whether the impounding of the bus, executed upon the verbal order of a police officer (Lopera) and without adherence to the normal judicial process, constitutes an unreasonable seizure violating the constitutional right "to be let alone."
How the issues of legal custody and deposit differ in context, especially regarding property held as evidence versus property unlawfully seized.

Whether the findings of the Court of Appeals (regarding the nature of the deposit and the custody exercised by Lopera) were appropriate in light of the constitutional and substantive rights at stake.
The applicability of exceptions to the rule against re-examination of facts, particularly when findings are based on overlooked undisputed evidence.