Case Summary (G.R. No. 198389)
Claims and Contracts
Plaintiffs had contracts with the Central to deliver their sugar cane for milling, with a profit-sharing arrangement specifying 60% of the processed sugar for the planters and 40% for the Central. The Central was responsible for informing planters about their sugar share via warehouse receipts. During the Japanese occupation, a significant amount of sugar was stored at the Central’s warehouse, which included approximately 128,452.24 piculs belonging to the plaintiffs.
Japanese Occupation and Sugar Sales
In 1943, the Japanese Military Administration empowered Fidel Henares, the president of the Planters' Association, to sell the sugar, resulting in sales under military regulation where existing claims by banks or enemy corporations were canceled. This led to further complications regarding ownership and distribution since both the Central and planters' sugars were sold without clear delineation of ownership. By the end of 1943, a considerable volume of sugar remained in the warehouse.
Batch Withdrawal and Legal Claims
Upon liberation, a consensus among planters led to a provisional distribution, with 60% assigned to them and 40% to the Central. Montelibano withdrew 12,789 piculs of sugar, some of which belonged to the Central, leading to claims by both parties regarding that sugar. The plaintiffs contended that they had already repaid for their share of the sugar sold during the occupation, while the Central claimed that all the sugar had been sold under military orders.
Court Proceedings and Trial Court Decision
The trial court ruled that the remaining sugar in the Central’s warehouse did not belong exclusively to plaintiffs since ownership depended on actual delivery. It applied provisions from the Spanish Civil Code related to mixed ownership, ruling that sugar remaining in the warehouse was subject to prorated distribution among original owners based on their shares before the military occupation. The court rejected the plaintiffs’ claims that their consent was required for the sales made during the occupation, deeming the sales valid despite the lack of individual approvals.
Legal Basis for Judgment
The court's decision underscored the principle that ownership of personal property is transferred upon actual delivery, thereby affirming the original owners' rights to the sugar in common ownership distinct from the Central. As a result, the court found in favor of the defendant concerning the co
...continue readingCase Syllabus (G.R. No. 198389)
Case Overview
- The case involves an appeal from both plaintiffs and defendants regarding a judgment from the Court of First Instance of Negros Occidental.
- Plaintiffs, Alfredo Montelibano and associates, sought recovery of P4,712,501.89 for sugar claimed to belong to them and stored in the defendant's warehouse during the Japanese occupation.
- The court ordered plaintiff Alfredo Montelibano to pay the defendant P35,163.06, plus legal interest from April 1945 until fully paid.
Parties Involved
- Plaintiffs: Alfredo Montelibano and other sugar planters, members of the Bacolod-Murcia Planters' Association, Inc.
- Defendant: Bacolod-Murcia Milling Co. (referred to as "Central"), a corporation processing sugar cane delivered by the planters.
Contractual Relationship
- The plaintiffs had contracts with the defendant for the delivery of their sugar cane to be processed into sugar, with a profit-sharing arrangement: 60% to the planter and 40% to the Central.
- The Central was responsible for providing planters with information about their sugar shares and warehouse receipts (quedans).
Context of the Case
- At the time of the Japanese occupation on May 21, 1942, 664,091.22 piculs of sugar were in the Central's warehouse, with 128,452.24 piculs belonging to the plaintiffs.
- Japanese Military Administration authorized the sale of sugar through the president of the Planters' Association, Fidel Henares.