GR 170202; (July, 2008) (Digest)
G.R. No. 170202; July 14, 2008
OPTIMUM MOTOR CENTER CORPORATION, Petitioner, vs. ANNIE TAN, doing business under the name & style “AJ & T Trading,” Respondent.
FACTS
Respondent Annie Tan, owner of an Isuzu cargo truck, delivered her vehicle to petitioner Optimum Motor Center Corporation for body repair, painting, and upholstery replacement under a verbal contract. The agreed completion date was February 15, 1994. Upon returning on that date, Tan was told the repairs were unfinished. Subsequent visits revealed the truck’s trade name had been scraped off, some parts were missing, and the vehicle was ultimately found abandoned and unrepaired at Optimum’s old shop. After Optimum vacated its premises due to an ejectment case, the truck was discovered in a dilapidated state at a new location in Valenzuela City. Tan filed a complaint for recovery of possession.
Optimum countered that repairs were completed by May 1994 but were delayed due to Tan’s failure to supply necessary materials. It asserted a possessory lien under Article 1731 of the Civil Code, claiming the right to retain the vehicle until unpaid repair costs were settled. The trial court found Optimum’s version unpersuasive, giving credence to the testimonies of neutral court personnel who witnessed the truck’s unrepaired and deteriorating condition months after the agreed completion date.
ISSUE
Whether Optimum Motor Center Corporation has a valid right to retain possession of the vehicle under a mechanic’s lien pursuant to Article 1731 of the Civil Code.
RULING
No. The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. A mechanic’s lien, which grants the right of retention to a repairman, is contingent upon the completion of the agreed work. The lien is an accessory right that presupposes the existence of a valid and fully performed contract for repairs. In this case, the factual findings of the lower courts, which are binding, established that Optimum failed to complete the repairs within the stipulated period or at any reasonable time thereafter. The truck was found unrepaired, partially dismantled, and in a worsening state. Since Optimum did not fulfill its contractual obligation, no right to compensation for repairs arose, and consequently, no possessory lien under Article 1731 could be validly exercised. The failure to perform the agreed work negates the very basis for the lien. Therefore, Optimum had no legal right to retain the vehicle and was ordered to return it or pay its value.