Case Summary (G.R. No. 96755)

Case Background

• Court: Supreme Court of the Philippines
• Date: December 4, 1991
• Petitioner: BPI Credit Corporation (formerly Filinvest Credit Corporation)
• Respondents: The Honorable Court of Appeals and Dominador Cabacungan
• Context: The case involves a petition for review concerning the return of payments and damages related to a seized vehicle under a chattel mortgage.

Trial Court Decision

• Outcome: The trial court ruled in favor of Cabacungan, ordering Filinvest to return P44,914.00, plus moral damages, exemplary damages, and attorney's fees.
• Judgment Highlights:
  • Filinvest was ordered to pay Cabacungan:
    • P44,914.00 for installment payments
    • P15,000.00 moral damages
    • P10,000.00 exemplary damages
    • P10,000.00 for attorney's fees
  • Other defendants were absolved of liability.

Legal Issues Presented

1. Lawfulness of Vehicle Seizure

   • Legal Principle: A mortgagee must provide a formal demand before seizing mortgaged property.
   • Key Details:
     • The seizure of the vehicle was deemed unlawful as no prior demand was made to Cabacungan.
     • The Deed of Chattel Mortgage required demand for the return of the vehicle.

2. Arrears in Payment

   • Legal Principle: The existence of delinquency in payments affects the rights of both parties under a chattel mortgage.
   • Key Details:
     • Cabacungan claimed he withheld payments to contest interest computations.
     • The trial court found that Cabacungan's account was not delinquent based on the evidence provided.

3. Damages Awarded

   • Legal Principle: Damages can be awarded based on the evidence of harm caused by unlawful actions.
   • Key Details:
     • The court upheld the award for moral and exemplary damages, supporting the trial court's findings.

Appellate Court Findings

• Appeal Rationale: Filinvest appealed the trial court's decision on grounds of erroneous conclusions and lack of substantial evidence.
• Court of Appeals Decision: Affirmed the trial court’s decision, emphasizing the sufficiency of evidence supporting Cabacungan's claims.

Supreme Court Ruling

• Decision: The Supreme Court modified the award to Cabacungan from P44,914.00 to P62,255.55 (the value of the vehicle) and affirmed other aspects of the lower court's ruling.
• Key Findings:
  • Filinvest's seizure of the vehicle was illegal.
  • Cabacungan was entitled to damages due to the unlawful seizure.
  • The court clarified provisions regarding the payment of docket fees and the nature of chattel mortgage as a contract of adhesion.

Legal Provisions and References

• Chattel Mortgage Law: Section 14 regarding the rights of the mortgagee upon default.
• Rules of Court: Section 9, Rule 60 governing replevin actions and damage claims.
• Contract of Adhesion: Defined as contracts where terms are drafted by one party, limiting negotiation by the other.

Key Takeaways

• The Supreme Court confirmed that a formal demand is required before seizing property under a chattel mortgage, reinforcing the principle of lawful possession.
• Filinvest's failure to demand the vehicle's return legally invalidated its seizure, leading to an award of damages to Cabacungan.
• The court's modification of the monetary award to reflect t...continue reading

Case Syllabus (G.R. No. 96755)

Case Overview

• This case originates from a petition for review by certiorari filed by BPI Credit Corporation (formerly Filinvest Credit Corporation) against the Court of Appeals and Dominador Cabacungan.
• The Court of Appeals affirmed the decision of the Regional Trial Court, which ruled in favor of Cabacungan, awarding him damages and ordering the return of payments made.

Factual Background

• In March 1982, Dominador Cabacungan purchased a brand new Isuzu KBD 26 pick-up vehicle on an installment basis from B.M. Domingo Motor Sales, Inc.
• The total price was P128,765.00, with an initial downpayment of P24,797.00 and a balance to be paid in 36 monthly installments of P2,888.00.
• The sale included a Deed of Chattel Mortgage, which secured the vehicle as collateral for the loan.
• B.M. Domingo Motor Sales, Inc. assigned its rights under the chattel mortgage and promissory note to Filinvest.
• From April 1982 to August 1983, Cabacungan made various installment payments but also made excess payments totaling P2,208.48.
• Cabacungan failed to make payments for June 1982 and February 1983, citing the need for a recomputation of interest due to overpayments.
• On September 13, 1983, Filinvest seized the vehicle without a prior court order or demand for its return, claiming Cabacungan was overdue on payments.

Procedural History

• Cabacungan filed a complaint for replevin after the seizure, alleging that Filinvest took the vehicle through force and intimidation.
• Filinvest denied using force, asserting that the vehicle was voluntarily surrendered by Cabacungan's employees.
• T...continue reading