Title
Villanueva vs. Spouses Salvador
Case
G.R. No. 139436
Decision Date
Jan 25, 2006
Spouses Salvador failed to redeem pawned jewelry; Ever Pawnshop auctioned items with defective notice. SC ruled sale invalid, deleted moral damages and attorney’s fees.

Case Digest (G.R. No. 110776)
Expanded Legal Reasoning Model

Facts:

  • Loan and Pawn Transactions
    • On December 20, 1991, respondents Spouses Alejo Salvador and Virginia Salvador (Salvadors) obtained a loan of ₱7,650.00 from petitioner Ever Pawnshop, managed by co-petitioner Enrico B. Villanueva.
    • On January 23, 1992, the Salvadors took out a second loan of ₱5,400.00 from Ever Pawnshop, again pledging jewelry items as security.
    • Pawnshop Ticket No. 29919 covered the first loan, with a redemption deadline of April 10, 1992; Pawnshop Ticket No. 30792 covered the second loan, with a redemption deadline of May 22, 1992.
  • Defaults, Payment, and Auction Notices
    • The Salvadors failed to redeem the pledged jewelry by the respective redemption dates.
    • On June 1, 1992, the Salvadors' son paid ₱7,000.00 to Ever Pawnshop, intended as partial payment for the first loan.
    • Pawnshop Ticket No. 29919 was canceled and replaced with Ticket No. 34932 to reflect this payment.
    • Ever Pawnshop extended the maturity date of the second loan to June 30, 1992, contingent on payment of 20% of the loan by June 4, 1992; no new pawn ticket was issued for this extension.
    • Ever Pawnshop published a notice in the Manila Bulletin on June 4, 1992, announcing a public auction sale scheduled on that same day for unpaid pledges for January 1–31, 1992.
    • On July 1, 1992, the Salvadors attempted to renew the second loan by paying the 20% but were informed the items had already been auctioned.
    • CA found some of the pawned jewelry still remained in the pawnshop, indicating either repurchase by Ever Pawnshop or incomplete auction sale.
    • On August 7, 1992, Mr. Salvador tendered payment on both loans and demanded the return of the jewelry, but Ever Pawnshop refused.
  • Litigation
    • On August 11, 1992, the Salvadors filed a complaint for damages against Villanueva and Ever Pawnshop for the unauthorized sale of pledged jewelry.
    • Shortly after summons was served, petitioners offered to accept payment and return the jewelry related to the first loan, which the Salvadors rejected.
    • Petitioners claimed they sent notices regarding maturity dates and auction sales, supported by letters dated March 23 and May 5, 1992, and a published notice in the Manila Bulletin.
    • The RTC ruled in favor of the Salvadors, ordering petitioners to pay ₱20,000.00 in moral damages, ₱5,400.00 as value of the second loan’s jewelry, ₱5,000.00 attorney’s fees, and costs of suit, and to return the jewelry covered by the first loan upon payment.
    • Petitioners appealed, but the Court of Appeals affirmed the RTC decision in toto.

Issues:

  • Whether the jewelry under the first loan was actually sold by petitioners.
  • Whether valid notice of sale of the pledged jewelry was given.
  • Whether the awards of ₱20,000.00 as moral damages and ₱5,000.00 as attorney’s fees are proper.
  • Whether the trial and appellate courts erred in ordering petitioners to pay damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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