GR 232814; (February, 2021) (Digest)
G.R. No. 232814 , February 03, 2021
POLICE SR. SUPT. ROMEO UY, SPO1 FELMANDIE TATLONGHARI, SPO1 MICHAEL AYCARDO, SPO1 GERRY GENTALLAN AND SPO1 ROMMEL FLORES AND JOHN DOES, PETITIONERS, VS. SERGIO JR. AND SALES V. JACALAN, RESPONDENTS.
FACTS
Respondents Sergio Jr. and Sales V. Jacalan purchased a second-hand Isuzu Wagon in 2006. The vehicle was registered in their names, and a PNP Motor Vehicle Clearance Certificate (MVCC) was issued, stating it was not listed as stolen and its engine/chassis numbers were “Not Tampered.” On March 7, 2008, respondents’ driver was apprehended by petitioners (police officers) for a seat belt violation and on suspicion that the vehicle’s OR/CR were spurious. The vehicle was impounded. Petitioners refused to release it, claiming the chassis and engine numbers were tampered and that it was reported stolen in 2004, allegedly belonging to Milamdec Foundation Inc. The vehicle was later transported to Camp Crame. Respondents filed a complaint for replevin. The RTC ruled in favor of respondents, ordering petitioners to pay solidarily the vehicle’s actual value (P475,000) with interest, moral damages, attorney’s fees, litigation expenses, and costs. The CA affirmed the RTC decision but noted the vehicle was not in custodia legis as its seizure was unlawful. Petitioners elevated the case to the Supreme Court.
ISSUE
Whether the Court of Appeals committed reversible error in: (1) directing the return of the actual value of the seized vehicle to respondents; and (2) ordering the payment of moral damages.
RULING
The petition is denied. The Supreme Court affirmed the CA decision with modification, deleting the award of attorney’s fees. The Court upheld the factual findings of the lower courts that respondents were the legitimate owners of the vehicle, having purchased it in good faith and for value. The seizure and impounding of the vehicle were unlawful. The act was not justified under the Seat Belts Use Act of 1999 (RA 8750), which only prescribes a fine or suspension for a seat belt violation. The vehicle was not in custodia legis as its seizure was unauthorized. Petitioners’ acts were ultra vires, making them personally and solidarily liable for the payment of the vehicle’s actual value with interest. The award of moral damages was sustained due to the humiliation and anxiety suffered by respondents from the unlawful seizure. However, the award of attorney’s fees was deleted as the RTC failed to state the basis for it in the body of its decision.