Title
Warehouse receipts issuance, transfer, and liability
Law
Act No. 2137
Decision Date
Feb 5, 1912
The Warehouse Receipts Act is a Philippine law that regulates the issuance, obligations, rights, negotiation, and transfer of warehouse receipts, with specific chapters addressing the essential terms of receipts, the obligations and rights of warehousemen, the negotiation and transfer of receipts, criminal offenses related to receipts, and interpretation and miscellaneous provisions.
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Required Contents of Warehouse Receipts

  • Must state location of the warehouse, date of issue, consecutive receipt number.
  • Must specify if goods will be delivered to bearer, specified person, or order.
  • Must include storage charge rates, description of goods or packages.
  • Must bear warehouseman’s signature or authorized agent’s signature.
  • If warehouseman owns the goods, receipt must state ownership.
  • Must list advances or liabilities for which a lien is claimed, or state if unknown.
  • Warehouseman liable for damages caused by omissions in required terms.

Additional Terms in Receipts

  • Warehouseman may include extra terms if not contrary to law or impairing duty of care.

Definition of Non-Negotiable and Negotiable Receipts

  • Non-negotiable: Goods delivered only to depositor or specific person.
  • Negotiable: Goods deliverable to bearer or to order named in receipt.
  • Any clause declaring negotiable receipt non-negotiable void.

Marking Duplicates and Non-Negotiable Receipts

  • Duplicate negotiable receipts must be marked "Duplicate" except original.
  • Failure to mark duplicates results in liability for damages.
  • Non-negotiable receipts must be plainly marked "nonnegotiable" or "not negotiable".
  • Failure to mark non-negotiable receipt allows holder who purchased for value to treat it as negotiable.

Warehouseman’s Obligation to Deliver Goods

  • Must deliver goods on demand accompanied by offer to satisfy lien, surrender negotiable receipt with indorsements, and readiness to acknowledge delivery.
  • Warehouseman bears burden to prove lawful excuse for refusal.

Justification and Liability in Deliveries

  • Justified to deliver to lawful possessor, authorized agent, or holder of negotiable receipt with proper indorsement.
  • Liable as for conversion if delivering goods to unauthorized parties.
  • Liability extends if requested not to deliver or informed of wrongful delivery.

Cancellation and Marking of Receipts upon Delivery

  • Negotiable receipts must be canceled upon delivery or warehouseman liable for failure to deliver to purchaser for value.
  • Partial delivery requires cancellation or marking stating what goods delivered, else liability arises.

Altered and Lost Receipts

  • Alterations excusing warehouseman only if material and fraudulent.
  • Authorized or immaterial alterations bind warehouseman.
  • Lost/destroyed negotiable receipts: court may order delivery upon bond and proof.
  • Delivery under court order does not relieve liability to bona fide purchasers without notice.

Effect of Duplicate Receipts

  • Duplicate receipt is warranty of accurate copy but imposes no other liability.

Warehouseman’s Title and Claims

  • Warehouseman’s own title or possession rights do not excuse refusal to deliver except when derived from depositor or lien.
  • Warehouseman may require interpleader in case of multiple claimants.
  • Excused from liability while ascertaining validity of adverse claims.
  • Adverse title is not a defense against depositor’s claim except as provided.

Liability for Goods Description and Care

  • Warehouseman liable if goods do not exist or differ from receipt description at issuance.
  • Statements of marks or depositor’s description do not create liability if true.
  • Liable for loss or injury from failure to exercise reasonable care.
  • Not liable for unavoidable loss despite care unless agreed otherwise.

Handling of Fungible and Commingled Goods

  • Goods of other depositors and separately receipted goods must be kept separate for identification.
  • Fungible goods may be commingled if authorized; ownership of mass held in common.
  • Warehouseman liable for care and redelivery of each depositor’s share.

Protection of Goods with Negotiable Receipts

  • Goods with negotiable receipts cannot be attached or levied upon without surrender or court injunction of the receipt.
  • Warehouseman not compelled to deliver goods without receipt surrendered or impounded.
  • Creditors can seek injunction or attachment of negotiable receipts under court aid.

Warehouseman’s Lien

  • Lien covers lawful storage, preservation charges, advances, interest, insurance, transportation, labor, weighing, coopering, notice, advertisement, and sale expenses.
  • Lien attaches on goods of liable debtor including goods deposited by debtor in possession of others.
  • Lien lost if warehouseman surrenders possession or refuses delivery unlawfully.
  • Charges other than storage must be enumerated in negotiable receipts to claim lien.
  • Warehouseman may refuse delivery until lien satisfied.
  • Lien does not exclude other legal remedies for collection.

Enforcement and Satisfaction of Liens

  • Written notice with claim details, goods description, payment demand, and sale threat must be given before sale.
  • Sale held publicly with advertisement unless goods are perishable or hazardous.
  • Sale proceeds pay lien and expenses; balance returned to owner or entitled person.
  • Perishable or hazardous goods may be sold or disposed without advertisement after notice.
  • Other lien enforcement remedies preserved.
  • After lawful sale or disposition, warehouseman not liable for failure to deliver.

Negotiation and Transfer of Receipts

  • Negotiation of negotiable receipts by delivery or indorsement.
  • Delivery negotiation applies when goods are deliverable to bearer or to order and indorsement in blank or to bearer given.
  • Indorsement may be blank, to bearer, or to specified person; subsequent indorsements permitted.
  • Non-negotiable receipts transferred by delivery but not negotiated; indorsement gives no extra rights.
  • Only owner or person entrusted with custody may negotiate receipts.

Rights of Holders and Transferees

  • Holder of negotiated receipt obtains good faith purchaser’s title and direct warehouseman obligation.
  • Transferee of non-negotiable receipt gains title against transferor and, upon notifying warehouseman, right against warehouseman.
  • Prior to notification, title may be defeated by creditor’s levy or subsequent transfer.
  • Transferee of negotiable receipt transferred without indorsement may compel indorsement.
  • Transfer by indorsement or delivery includes warranties of genuineness, right to transfer, knowledge of no impairing facts, and merchantability.
  • Indorser not guarantor of warehouseman’s or predecessors’ performance.
  • Payment acceptance by security holder does not imply warranty of receipt or goods.
  • Negotiation valid despite prior breach of duty, fraud, mistake, or duress if transferee paid in good faith.
  • Subsequent negotiation of receipt by person retaining possession authorized where purchaser acts in good faith.
  • Negotiation extinguishes vendor’s lien or stoppage in transitu; warehouseman not obliged to deliver without cancellation of receipt.

Criminal Offenses and Penalties

  • Issuing receipt without actual goods or control: imprisonment up to 5 years and/or fine up to 10,000 pesos.
  • Fraudulent receipt issuance with false statements: imprisonment up to 1 year and/or fine up to 2,000 pesos.
  • Issuing unmarked duplicate negotiable receipts: imprisonment up to 5 years and/or fine up to 10,000 pesos.
  • Failure to state warehouseman’s ownership of goods on negotiable receipts: imprisonment up to 1 year and/or fine up to 2,000 pesos.
  • Delivering goods without obtaining negotiable receipt while one outstanding: imprisonment up to 1 year and/or fine up to 2,000 pesos.
  • Negotiating receipt for goods without title or liens with intent to deceive: imprisonment up to 1 year and/or fine up to 2,000 pesos.

Interpretation, Definitions, and Application

  • Cases not covered by Act governed by existing laws or law merchant.
  • Definitions provided for key terms: action, delivery, fungible goods, goods, holder, order, owner, person, purchase, purchaser, receipt, value, warehouseman, good faith.
  • Act applies only to receipts issued after its effectivity.
  • Repeals inconsistent laws.
  • Act takes effect ninety days after publication.

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