Case Summary (G.R. No. 166494)
Petitioner
William Anghian Siy alleged that he acquired the vehicle from Lopez on July 22, 2009, by deed of sale executed in blank, and entrusted it to Ong for sale. Ong failed to remit the proceeds or return the vehicle, which passed in turn to Chua and then to respondent Tomlin.
Respondent
Alvin Tomlin purchased the vehicle from Chua on December 7, 2010, caused its registration in his name on March 7, 2011, and attempted to secure a PNP clearance.
Key Dates
- July 22, 2009: Lopez sells vehicle to Siy.
- September 2010: Siy delivers vehicle and blank deed to Ong.
- December 7, 2010: Chua sells vehicle to Tomlin.
- March 7, 2011: LTO issues Certificate of Registration in Tomlin’s name.
- July 29, 2011: RTC issues writ of replevin upon ₱8 million bond.
- August 17, 2011: Tomlin moves to quash replevin.
- November 21, 2011: RTC denies Tomlin’s omnibus motion.
- October 9, 2012: CA grants certiorari, dismisses replevin case.
- April 24, 2017: Supreme Court renders decision.
Applicable Law
- 1987 Philippine Constitution (governing post-1990 decisions).
- Rule 60, 1997 Rules of Civil Procedure (Replevin).
- Civil Code of the Philippines, Articles 1869–1870 (Agency).
Factual Background
Siy entrusted the vehicle and title documents to Ong as his sales agent. Ong sold it to Chua without remitting payment; the vehicle was then sold to Tomlin, who registered ownership. Siy filed police complaints for estafa and carnapping against Ong, then a replevin suit to recover possession.
Trial Court Proceedings and Ruling
In Civil Case No. Q-11-69644, the RTC granted Siy’s application for a writ of replevin upon posting bond. Tomlin filed an omnibus motion to quash, arguing undervaluation (docket‐fee fraud), defective pleading under Rule 60 (missing allegations of wrongful detention, custodia legis, actual market value), and improper service. The RTC denied the motion, holding that jurisdiction and remedy issues were best resolved at trial and that Tomlin’s remedy was to post a counterbond.
Court of Appeals Decision
The CA granted Tomlin’s petition for certiorari. It held that the RTC lacked jurisdiction because Siy misdeclared the vehicle’s value (₱2 million vs. actual ₱4.5–5 million) to underpay docket fees and failed to comply with Rule 60’s affidavit requirements. It further found the writ improperly served post-seizure and that the correct remedy was to quash the writ. It dismissed the replevin case and ordered the vehicle returned to the PNP-HPG.
Issues on Appeal
- Whether the RTC acquired jurisdiction over the replevin complaint.
- Whether Siy’s complaint and affidavit satisfied Rule 60, Sections 2 and 4.
- Whether the writ of replevin was properly served.
Petitioner’s Arguments
Siy maintained that his valuation was made in good faith, that the trial court could allow completion of docket‐fee payment, that he substantially complied with Rule 60, and that service of the writ by delivering copies post-seizure was sufficient.
Respondent’s Arguments
Tomlin argued that the undervaluation was intentional fraud, that Rule 60’s specified allegations must appear verbatim or specifically, that Siy lacked both ownership and right to possession, and that he himself purchased and registered in good faith.
Supreme Court’s Analysis: Ownership and Possession
Under the 1987 Constitution and Civil Code, replevin requires that the claimant be owner or entitled to possession. An agency arose when Siy left the vehicle, blank deed, and title documents wit
Case Syllabus (G.R. No. 166494)
Factual Antecedents
- Petitioner William Anghian Siy purchased a 2007 Range Rover (Plate ZMG 272) from Alberto Lopez III on July 22, 2009; Lopez executed and signed a deed of sale in blank and delivered all title documents to petitioner.
- In 2010, petitioner entrusted the vehicle and documents to Frankie Domanog Ong, owner of a second-hand car showroom (“Motortrend”), to find a buyer; Ong issued two bounced guarantee checks totaling ₱4.95 million instead of remitting proceeds.
- Ong sold the vehicle to John Co Chua using the blank deed; Chua later sold it by deed dated December 7, 2010, to respondent Alvin Tomlin, who registered title in his name on March 7, 2011.
- Petitioner filed a “Failed to Return Vehicle” report with the Quezon City Police’s Anti-Carnapping Section and later filed formal estafa and carnapping complaints against Ong and Centeno.
- When respondent attempted to obtain PNP clearance to transfer title, the PNP-HPG impounded the vehicle at Camp Crame.
Trial Court Proceedings
- July 2011: Petitioner filed Civil Case No. Q-11-69644 (Complaint for Recovery of Possession with Prayer for Replevin) against Ong, Centeno, Chua, and Tomlin before RTC Branch 224, Quezon City.
- RTC granted petitioner’s application for a writ of replevin (July 29, 2011) upon admission of documentary exhibits, subject to an ₱8 million bond—posted and approved.
- The special sheriff seized the Range Rover and filed a Sheriff’s Return.
- August 17, 2011: Respondent filed an Omnibus Motion to quash the writ, dismiss the complaint for failure to pay correct docket fees, alleged procedural defects, defective ownership allegations, and asserted his registered ownership.
- Petitioner opposed.
Ruling of the Regional Trial Court
- November 21, 2011: RTC denied respondent’s Omnibus Motion for lack of merit, holding that:
- Respondent’s remedy was to post a counterbond under Rule 60, no