G.R. No. 26278 , August 4, 1927
LEON SIBAL, plaintiff-appellant, vs. EMILIANO J. VALDEZ ET AL., defendants. EMILIANO J. VALDEZ, appellee.

FACTS

Leon Sibal filed an action against Emiliano J. Valdez and Deputy Sheriff Vitaliano Mamawal. Sibal sought to redeem sugar cane attached and sold to Valdez via execution, and to recover palay allegedly harvested by Valdez from certain parcels of land. Sibal also obtained a preliminary injunction to prevent Valdez from harvesting the crops.

The properties involved had a complex history of attachments and sales due to separate judgments against Sibal. Initially, eight parcels of Sibal’s land were attached and sold at auction to Macondray & Co. (July 30, 1923). Sibal made a partial redemption payment. Later, Valdez obtained a judgment against Sibal. Under this judgment, the sheriff attached Sibal’s personal property, including the standing sugar cane, and sold it to Valdez (May 1924). Subsequently, Macondray & Co. sold all the land it had acquired to Valdez (June 25, 1924).

Valdez argued the sugar cane was personal property and not subject to legal redemption, and claimed ownership of some parcels and the palay planted thereon. The trial court ruled in favor of Valdez, holding the sugar cane was personal property and not redeemable, and awarded Valdez damages for losses caused by the injunction. Sibal appealed.

ISSUE

1. Whether the sugar cane, as a growing crop attached and sold separately from the land, is considered personal property and therefore not subject to the right of legal redemption under the rules of execution sale.
2. Whether the trial court correctly adjudicated ownership of the parcels and palay, and properly computed the damages awarded to Valdez for losses due to the injunction.

RULING

The Supreme Court AFFIRMED the trial court’s judgment with MODIFICATIONS to the amount of damages.

1. On the Nature of the Sugar Cane: The Supreme Court upheld the trial court’s ruling that the sugar cane, having been levied upon and sold as personal property under a writ of execution directed at Sibal’s personal assets, was correctly treated as chattel. Consequently, it was not subject to the right of legal redemption which applies only to real property sold at execution sale. The fact that the land was later sold to Valdez did not retroactively change the nature of the prior separate sale of the crop.

2. On Damages: The Court recalculated the damages Valdez was prevented from earning due to the wrongful injunction, based on the evidence.
* Sugar Cane: The award of P6,757.40 for the unharvested sugar cane was sustained.
* Sugar Cane Shoots: The award was reduced from P1,435.68 to P1,220.40 based on a corrected computation of the quantity.
* Palay Harvested by Sibal: The award was reduced from P646 to P323, as only half of the 190 cavans harvested from the disputed parcels belonged to Valdez as landowner, with the other half belonging to Sibal as planter.
* Lost Palay Cultivation: The award of P600 for the palay Valdez could not plant due to the injunction was sustained.

The Court modified the total damages to P8,900.80, to be paid jointly and severally by Sibal and his sureties. The rest of the trial court’s judgment was affirmed.