Title
Bonjoc vs. Cuison
Case
G.R. No. 3413
Decision Date
Mar 27, 1909
Defendant destroyed plaintiffs' house, claiming ownership via a disputed debt guarantee document. Court ruled house remained plaintiffs' property, awarding ₱500 compensation and ₱150 damages for unlawful destruction.
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Case Summary (G.R. No. 3413)

Case Background

  • Parties Involved: Pomposa Bonjoc et al. (Plaintiffs/Appellees) vs. Candelario Cuison (Defendant/Appellant).
  • Court: Supreme Court of the Philippines.
  • Judgment Date: March 27, 1909.

Ownership and Destruction of Property

  • Legal Principle: The main issue is whether the house destroyed by the defendant belonged to the plaintiff or the defendant at the time of destruction.
  • Key Definitions:
    • Guaranty: A provision where a debtor provides an asset as security for a debt.
  • Important Findings:
    • The defendant admitted the house originally belonged to the plaintiff.
    • The defendant claimed that the plaintiff assigned the house to him as security for a debt owed by her deceased husband.
    • The court found that the document (Exhibit 2) presented by the defendant did not transfer ownership but merely served as a security.

Evidence and Testimony

  • Procedures:
    • Testimonies from both the plaintiff and the defendant's witnesses were presented.
    • The defendant's assertion that the house was given as security was corroborated by his witnesses, but the court deemed their testimonies suspicious due to conflicting accounts.
  • Key Details:
    • The defendant's witnesses had inconsistencies regarding the authorship of the document.
    • The court noted that the execution of the document was not conclusively proven.

Court’s Ruling on Damages

  • Legal Principle: The court addressed the plaintiffs' demand for compensation due to the destruction of the house.
  • Procedures:
    • The trial court sentenced the defendant to pay 500 pesos as compensation for the destroyed property.
    • The plaintiffs also sought compensation for losses and damages amounting to 150 pesos due to deprivation of use.
  • Consequences:
    • The defendant was found liable for both the value of the destroyed house and additional damages.

Interest on Damages

  • Legal Principle: The issue of whether legal interest should be applied to the compensation owed to the plaintiffs.
  • Key Findings:
    • The court determined that interest was not applicable in this case as it pertained to indemnity for damages caused by the unlawful destruction of property, not a debt default.

Conclusion and Affirmation

  • Final Judgment: The Supreme Court affirmed the lower court's decision, ordering the defendant to pay damages with costs against him.
  • Cross-References:
    • The judgment referenced Section 90 and Section 126 of the Code of Civil Procedure regarding equitable relief and the authority of the court to grant remedies not specifically requested.

Key Takeaways

  • The destruction of property owned by another without lawful authority constitutes a violation of ownership rights.
  • Security agreements do not inherently transfer ownership unless explicitly stat...continue reading

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