Title
People vs Razon
Case
G.R. No. L-13333
Decision Date
Mar 21, 1918
A tenant farmer, accused of violating the Chattel Mortgage Law by selling mortgaged palay without consent, was acquitted due to insufficient evidence and ambiguous mortgage terms, with the Court ruling the dispute civil, not criminal.

Case Digest (A.M. No. MTJ-00-1270)
Expanded Legal Reasoning Model

Facts:

  • Parties Involved:
    • Plaintiff and Appellee: The United States.
    • Defendants: Brigido Razon and Martina Tayag.
    • Appellant: Brigido Razon.
  • Nature of the Case:
    • The case involves criminal charges based on a civil transaction, specifically the alleged violation of Sections 10 and 12 of the Chattel Mortgage Law (Act No. 1508).
  • Chattel Mortgage Agreement:
    • Mortgagor: Brigido Razon, a tenant farmer.
    • Mortgagee: Pedro N. Liongson, the landowner.
    • Terms of the Mortgage:
      • Razon mortgaged a harvest of palay (rice) planted on Liongson’s land to secure a debt of P1,534.50 and 530 cavans of palay.
      • The harvest was expected in January and February 1917.
      • Razon agreed not to sell, transfer, or mortgage the palay without Liongson’s written consent.
  • Alleged Violation:
    • On July 3, 1917, an information was filed accusing Razon and his wife of violating the Chattel Mortgage Law by disposing of a portion of the mortgaged palay without Liongson’s consent, intending to defraud him.
  • Trial Proceedings:
    • The demurrer for Martina Tayag was sustained, and the trial proceeded only against Brigido Razon.
    • The trial court found Razon guilty and sentenced him to pay a fine of P4,295, half of the costs, and subsidiary imprisonment in case of insolvency.
  • Key Evidence:
    • The mortgage document.
    • Testimonies regarding the amount of palay harvested and sold.
    • A summary of accounts (Exhibit C) submitted by Liongson.

Issues:

  • Sufficiency of Evidence:
    • Whether the evidence sufficiently proved that the mortgaged palay was sold without the mortgagee’s consent.
  • Admissibility of Evidence:
    • Whether Exhibit C (summary of accounts) was properly admitted as evidence.
    • Whether certain statements by Razon constituted confessions or mere admissions.
  • Corpus Delicti:
    • Whether the palay allegedly sold was covered by the mortgage.
  • Amount of Palay Harvested:
    • Whether the court correctly determined the amount of palay harvested and sold by Razon.
  • Equity and Usury:
    • Whether the mortgage terms were equitable or involved usurious interest.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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