Title
Cerna vs. Court of Appeals
Case
G.R. No. L-48359
Decision Date
Mar 30, 1993
Cerna, not a signatory to a promissory note, was sued for a loan secured by a chattel mortgage. Court ruled he wasn’t liable, filing a collection suit abandoned the mortgage, and res judicata barred subsequent motions.

Case Summary (G.R. No. L-48359)

Petitioner

Manolo P. Cerna was neither a signatory to the promissory note nor the chattel mortgage. He had executed a Special Power of Attorney in favor of Delgado authorizing Delgado to mortgage petitioner’s Taunus automobile. Petitioner consistently denied that he was a debtor or co-mortgagor, alleged Delgado’s death and the need to proceed against Delgado’s estate, and claimed the special power of attorney might be forged.

Respondent

Conrad C. Leviste extended a loan evidenced by a promissory note signed by Delgado alone and proceeded to secure the obligation by a chattel mortgage (which, in form, referenced Delgado acting as attorney-in-fact for petitioner). Leviste filed a collection suit for the unpaid promissory note against Delgado and petitioner as alleged solidary debtors.

Key Dates and Procedural Milestones

  • October 16, 1972: Promissory note executed by Delgado; chattel mortgage executed by Delgado (authorizing mortgage over petitioner’s automobile via Special Power of Attorney).
  • April 4, 1973: Petitioner’s first motion to dismiss filed in trial court (grounds: lack of cause of action, Delgado’s death, abandonment of mortgage).
  • June 28, 1976: Court of Appeals denied first certiorari petition (CA G.R. No. 03088).
  • February–May 1977: Second motion to dismiss filed and denied by trial court.
  • March 31, 1978: Court of Appeals granted relief insofar as action against Delgado and denied relief as to petitioner (CA G.R. No. SP-07237).
  • March 30, 1993: Supreme Court decision dismissing petitioner’s review petition on procedural grounds (while addressing substantive points).

Applicable Law and Authorities Cited

  • Civil Code: Art. 1311 (contracts take effect only between the parties), Art. 1207 (solidary liability requires express stipulation, law, or nature of obligation), Art. 2085 (requisites for pledge and mortgage, including authority to dispose of property).
  • Rules of Court / Code of Civil Procedure: Section 7, Rule 86, and Sec. 708 (treatment of mortgage debts against a deceased estate and the creditor’s election between foreclosure and proving as a claim against the estate).
  • Precedent and doctrine cited in the decision: Osorio v. San Agustin (interpretation of creditor’s election re: mortgage vs. proving claim), Banco de Oro v. Bayuga, People v. Mata, and scholarly authority (Agbayani, Commercial Laws).

Facts

Delgado executed a promissory note promising payment of P17,500 at 12% interest and, on the same date, executed a chattel mortgage over his Willy’s jeep and, acting as petitioner’s attorney-in-fact, mortgaged petitioner’s Taunus. Delgado defaulted. Leviste filed a collection suit against Delgado and petitioner as solidary debtors. Petitioner moved to dismiss repeatedly, asserting lack of cause of action against him, Delgado’s death (and the need to proceed against the estate), and that Leviste’s prosecution of a collection suit constituted abandonment of the chattel mortgage remedy.

Procedural History

Petitioner’s first motion to dismiss was denied by the trial court. He pursued a certiorari petition to the Court of Appeals, which was denied for failure to prove Delgado’s death and alleged forgery of the special power. After a second motion to dismiss was denied, petitioner again sought certiorari; the Court of Appeals dismissed his petition insofar as it sought relief against petitioner but granted relief as to Delgado. Petitioner brought a petition for review to the Supreme Court.

Issue Presented

Whether the complaint for recovery of money based on a promissory note should have been dismissed as to petitioner, where petitioner did not sign the note and had only granted Delgado a special power of attorney to mortgage petitioner’s car—specifically, whether the filing of a collection suit by the mortgagee operated as an abandonment of the chattel mortgage and thereby precluded recovery against petitioner.

Court’s Substantive Analysis on Liability

The Supreme Court rejected the Court of Appeals’ conclusion that petitioner was solidarily liable. The Court emphasized the foundational principle that contracts bind only the parties who contract (Civil Code, Art. 1311). Because only Delgado signed the promissory note, petitioner was not a party to the loan contract and was not a debtor under the note. Solidary liability exists only where expressly provided or required by law or by the nature of the obligation (Civil Code, Art. 1207); neither the promissory note nor the mortgage explicitly made petitioner a solidary obligor. The chattel mortgage was characterized as accessory to the principal loan contract; the fact that a third party’s property was used as security under authority of a special power of attorney did not, by itself, make the third-party owner (petitioner) a co-debtor or co-mortgagor. The special power of attorney merely authorized Delgado to mortgage petitioner’s property and satisfied the requirement in Article 2085 that the mortgagor have free disposal of the property or be legally authorized.

Court’s Substantive Analysis on Election of Remedies

The Court agreed with petitioner that a mortgagee who elects to file a suit for collection (seeking a money judgment) abandons the remedy of foreclosure of the chattel mortgage. Citing doctrinal authority and precedent, the decision explains that when a mortgagee proceeds by collection action rather than foreclosing the security, the mortgagee manifests an abandonment of the mortgaged property as the basis for relief. Consequently, once Leviste elected to sue on the promissory note (a money claim) he could not thereafter pursue the mortgaged third-party’s personal liability by foreclosing the mortgage. This rule is further reinforced where the principal debtor is deceased: Section 7, Rule 86 (and its predecessor Sec. 708) permit a creditor holding a claim secured by mortgage against a deceased to either abandon the security and prove the claim against the estate or to foreclose the mortgage and realize upon the security, but not both; the law affords the creditor a choice, and electing one remedy precludes the other (as explained in Osorio v. San Agustin).

Procedural Bar: Res Judicata and Abuse of Process

Although the Court found merit in petitioner’s substantive arguments, it denied the petition on procedural grounds. The Supreme Court held that petitioner’s repetitive petitions amounted to an attempt to circumvent the finality of the earlier Court of Appeals decision (CA G.R. No. 03088) and c

    ...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.