G.R. No. 128797 November 19, 1999
FIRST NATIONWIDE ASSURANCE CORPORATION, petitioner, vs. COURT OF APPEALS, Col. MANUEL BRUAN in his capacity as group commander of the Constabulary Highway Patrol Group, and/or JOHN DOE, respondents, EDUARDO CONDE, intervenor-respondent.

FACTS

Petitioner First Nationwide Assurance Corporation insured a 1987 Mitsubishi Pajero registered to Gerald Brimo, which was carnapped on June 5, 1988. After indemnifying Brimo, the insurer was subrogated to his rights. Meanwhile, intervenor-respondent Eduardo Conde purchased a similar Pajero from Gregorio Elardo in July 1988 in Bacolod City. Conde verified the vehicle’s documents with the LTO and the Constabulary Highway Patrol Group (CHPG) before purchase. The CHPG later seized the vehicle on suspicion it was the carnapped unit. An initial macro-etching test in Manila showed no tampering, and a “no record” certification was issued.
Subsequent investigations revealed serious discrepancies. A second macro-etching by the PC-INP Crime Laboratory in Bacolod, conducted in the presence of Conde and CHPG officers, found filings on the chassis number, altering a digit from “3” to “5”. Furthermore, the registration documents presented by Conde were discovered to be spurious. The Certificate of Registration was issued by an LTO office that did not correspond to its series number, and the plate number was assigned to a different vehicle owned by another person.

ISSUE

Whether the Court of Appeals erred in reversing the trial court and awarding ownership and possession of the disputed vehicle to intervenor Eduardo Conde.

RULING

Yes, the Supreme Court reversed the Court of Appeals and reinstated the trial court’s judgment declaring petitioner as the lawful owner. While factual findings of the CA are generally conclusive, the Court may review them when, as here, its conclusions contradict those of the trial court. The CA’s decision was based on a misappreciation of evidence, relying on the initial “no record” macro-etching result while ignoring the substantial contrary evidence.
The legal logic centers on the preponderance of evidence establishing the vehicle’s identity. The second, more credible macro-etching examination conclusively proved the chassis number was tampered with, directly linking Conde’s vehicle to the stolen unit. This finding was corroborated by the fraudulent nature of the registration documents, which were issued by the wrong LTO office and bore a plate number belonging to another vehicle. Conde failed to overcome this evidence or prove he was a purchaser in good faith. In contrast, petitioner, as Brimo’s insurer and subrogee, successfully traced the carnapped vehicle through competent police investigation and forensic evidence. Therefore, ownership rightfully reverts to the insurer. The CA’s reliance on the first macro-etching, conducted without proper documentation and later superseded by a more thorough examination, constituted reversible error.