Title
Ago vs. Court of Appeals
Case
G.R. No. L-17898
Decision Date
Oct 31, 1962
Petitioner defaulted on payments for sawmill machinery, leading to foreclosure. Supreme Court ruled execution void due to lack of proper notice, deemed machinery immovable, and invalidated sheriff's sale for non-compliance with publication rules.

Case Summary (G.R. No. L-17898)

Petitioner and Respondents

Petitioner bought sawmill machineries and executed a chattel mortgage in favor of Grace Park Engineering, Inc. Respondents include the mortgagee (Grace Park), the trial judge who dictated a judgment on compromise, the provincial sheriff who levied and sold the goods, and the Court of Appeals that earlier ruled on the petition for certiorari and preliminary injunction.

Key Dates

  • 1957: Purchase of machineries and execution of chattel mortgage; unpaid balance P32,000.00.
  • 1958: Extrajudicial foreclosure instituted by Grace Park.
  • January 28, 1959: Trial judge dictated a judgment in open court based on a written compromise.
  • August 15, 1959: Court of First Instance issued an order granting execution.
  • September 23, 1959: Writ of execution dated.
  • September 25, 1959: Counsel for petitioner allegedly received a copy of the judgment.
  • December 1, 1959: Petitioner filed certiorari and prohibition with preliminary injunction in Court of Appeals.
  • December 4, 1959: Sheriff conducted public auction; Grace Park was sole bidder (P15,000).
  • December 8, 1959: Court of Appeals issued writ of preliminary injunction (after sale).
  • November 9, 1960: Court of Appeals rendered decision dismissing petition and dissolving injunction.
  • October 31, 1962: Supreme Court decision under review.

Applicable Law and Precedents

Applicable constitutional framework: the 1935 Philippine Constitution (decision before 1990). Relevant procedural and substantive provisions quoted or applied in the decision: Rule 35, Section 1 (how judgments are to be rendered — written, personally prepared by judge, signed, and filed with clerk); Rule 27, Section 7 (service of final orders or judgments — personally or by registered mail); Rule 39, Section 16(c) (notice of sale for real property, including posting and publication where assessed value exceeds prescribed amount); Civil Code Article 415(5) (definition of immovable property including machinery intended by owner of tenement for an industry or works in a building); and pertinent precedents cited in the record (De los Reyes v. Ugarte; Berkenkotter v. Cu Unjieng y Hijos).

Factual Background

Pastor Ago purchased sawmill machineries from Grace Park and secured payment with a chattel mortgage. After defaults, Grace Park initiated extrajudicial foreclosure; petitioner filed an action to enjoin foreclosure. The parties executed a written compromise submitted and accepted in court; the trial judge then dictated a decision in open court on January 28, 1959. Petitioner allegedly continued defaulting under the compromise judgment, prompting Grace Park to move for execution; the trial court granted execution and issued a writ. The sheriff levied on and later sold the machineries, which petitioner had assigned to Golden Pacific Sawmill, Inc., and which had been installed in Golden Pacific’s building before the sheriff’s levy and sale.

Procedural History

Petitioner moved for reconsideration alleging lack of formal and valid notice; the trial court denied it. Petitioner then petitioned the Court of Appeals for certiorari and prohibition with a preliminary injunction, alleging (a) lack of valid service of the judgment prior to issuance of execution, (b) illegality of the sheriff’s sale, and (c) that the machineries had become real property of Golden Pacific Sawmill, Inc. The Court of Appeals concluded the open-court dictation constituted sufficient notice and dismissed the petition, dissolving the preliminary injunction; the Court of Appeals’ order was then reviewed by the Supreme Court.

Issues Presented

  1. Whether the judge’s pronouncement of the compromise judgment in open court constituted rendition of judgment and sufficient notice to petitioner for purposes of issuance of execution.
  2. Whether the sheriff’s public auction sale was valid, including whether notice and publication requirements were observed.
  3. Whether the machineries were movable chattels or had become immovable property (real estate) by reason of installation and use.

Supreme Court’s Analysis — Rendition and Notice of Judgment

The Court applied Rule 35, Section 1: judgments deciding the merits must be in writing, personally and directly prepared by the judge, signed by him, and filed with the clerk of court. A mere oral pronouncement in open court with stenographic notes does not constitute rendition. The Court explained that until a signed judgment is filed with the clerk it remains subject to amendment or change by the judge and therefore is not the binding judgment of the court. Concerning notice, Rule 27, Section 7 requires service of final orders or judgments either personally or by registered mail. Thus the mere presence of a party or counsel in court when a judge dictates a decision is not equivalent to service of the signed, filed judgment; such hearing is not effective notice for purposes of starting post-judgment processes. Because the writ of execution issued and the subsequent enforcement steps occurred before the petitioner had been served with the signed, filed judgment in the manner required by the Rules, the issuance of the writ of execution was null and void.

Supreme Court’s Analysis — Nature of Machineries (Movable vs. Immovable)

Applying Article 415(5) of the Civil Code and the Court’s prior decision in Berkenkotter v. Cu Unjieng y Hijos, the Court held that machinery intended by the owner of the tenement for an industry or works carried on in a building and which tends directly to meet the needs of that industry becomes immovable by reason of its purpose and installation. Here, the sawmill machineries had been installed in Golden Pacific Sawmill, Inc.’s building for use in the sawing of logs and thus became a nece

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.