Case Summary (G.R. No. 232849)
Procedural History
- December 14, 1924 – Leon Sibal sues in the Court of First Instance of Tarlac seeking redemption of sugar cane sold at execution and injunction against harvesting of cane and palay.
- December 27, 1924 – Trial court grants preliminary injunction upon Sibal’s ₱6,000 bond.
- April 28, 1926 – Trial court holds sugar cane personal property (non‐redeemable), absolves Valdez of liability, and awards Valdez ₱9,439.08 for cane, cane shoots, and palay losses.
- Appeal to the Supreme Court of the Philippine Islands (G.R. No. 26278).
Facts
• May 11, 1923 – Sheriff attaches eight parcels of Leon Sibal’s land under execution in favor of Macondray & Co.
• July 30, 1923 – Macondray & Co. buys parcels at auction for ₱4,273.93.
• September 24, 1923 – Sibal pays ₱2,000 toward redemption, reducing balance to ₱2,579.97.
• April 29, 1924 – Under a separate writ in favor of Valdez, Mamawal attaches Sibal’s growing sugar cane (seven parcels) and his real property (eleven parcels).
• May 9–10, 1924 – Valdez purchases attached sugar cane for ₱600.
• June 25, 1924 – Valdez buys eight of Sibal’s real‐estate parcels for ₱12,200 and acquires Macondray’s redemption rights for ₱2,579.97.
Issues on Appeal
- Whether ungathered sugar cane is real or personal property and thus redeemable.
- Ownership of parcels 1, 2, and 7 (and a parcel in Pacalcal) described in Sibal’s complaint.
- Proper computation of Valdez’s losses in sugar cane, cane shoots, and palay due to injunction.
- Allocation of palay crop harvested by Sibal on parcels belonging to Valdez.
Applicable Law
• Civil Code (1916), art. 334(2): “Trees, plants, and ungathered products…part of immovable.”
• Code of Civil Procedure, sec. 450: all real and personal property subject to execution.
• Act No. 1508 (Chattel Mortgage Law): expressly treats growing crops as personal property.
Nature of Growing Crops
The Court adopts prevailing Spanish, Louisiana, and U.S. jurisprudence recognizing that while growing crops may be “immovable” in abstracto, rights acquired in them by anticipation render them movable. Section 450 CCP and the Chattel Mortgage Law treat ungathered products as personal property for execution and mortgage purposes. Accordingly, sugar cane is not redeemable after sale.
Ownership of Disputed Parcels
• Parcels 1 & 2 (complaint): trial evidence and comparison of land descriptions establish these parcels were sold to Macondray in July 1923 and conveyed to Valdez on June 25, 1924. Any claimed interest of third parties was unsupported.
• Parcel 7 and the Pacalcal parcel: similarly correspond to lots purchased by Valdez both from the sheriff’s sale and from Macondray, rendering him absolute owner of those tracts.
Computation of Damages and Crop Allocations
• Sugar cane: 22.60 ha would yield 1,039.60 picos; half (519.80) belonged to Valdez. At ₱13/pico, net ₱6,757.40.
• Cane shoots: 1,017,000 shoots a
Case Syllabus (G.R. No. 232849)
Facts
- On December 14, 1924, Leon Sibal filed suit in the Court of First Instance, Province of Tarlac, claiming wrongful attachment and sale of his sugar-cane crop and improper harvesting of his palay by Emiliano J. Valdez.
- First cause of action: Deputy Sheriff Vitaliano Mamawal, under a Pampanga writ of execution, attached and sold plaintiff’s sugar cane on seven parcels; Sibal tendered redemption within one year, but Valdez refused both money and return of crop.
- Second cause of action: Valdez had harvested 300 cavans of palay from four of the seven parcels and was attempting to harvest more; Sibal alleged all palay belonged to him.
- Sibal sought (1) preliminary injunction restraining Valdez from disturbing possession or harvesting cane and palay, and (2) judgment compelling Valdez to accept redemption and damages of ₱1,056 for palay taken.
- On December 27, 1924, the trial court granted the preliminary injunction upon Sibal’s ₱6,000 bond.
Procedural History
- Valdez’s amended answer: denied all allegations; defenses included that sugar cane is personal property not redeemable, and that he owned parcels 1, 2, 7 and corresponding palay, and had not harvested in some parcels.
- Valdez counterclaimed for loss of sugar cane, cane shoots, and palay due to injunction (₱8,375.20) plus additional damages (₱3,458.56), praying for declaratory relief of ownership and ₱11,833.76 in damages.
- After trial, on April 28, 1926, Judge Lukban ruled:
• Sugar cane is personal property not subject to redemption
• Defendants absolved from liability
• Sibal and his sureties jointly required to pay Valdez ₱9,439.08 (breakdown: ₱6,757.40 cane; ₱1,435.68 shoots; ₱646 palay already harvested; ₱600 lost palay). - Sibal appealed, assigning error to (1) characterization of sugar cane, (2) parcel ownership findings, (3) calculation of lost cane and shoots, (4) calculation of lost palay, and (5) amount of monetary award.
Issues
- Whether the attached and sold sugar cane constituted real or personal property and was redeemable.
- The true ownership of the disputed parcels (Nos. 1, 2, 7 and the additional parcel in the second cause).
- Proper measure of Valdez’s losses: sugar cane, s