GR 47981; (July, 1989) (Digest)
G.R. No. 47981 , July 24, 1989
JUAN V. SABINOSA, petitioner, vs. THE HONORABLE COURT OF APPEALS, BIENVENIDO F. BUNYI, and MARIANITO P. BAUTISTA, respondents.
FACTS
Marianito P. Bautista borrowed P33,000.00 from Bienvenido F. Bunyi to pay for the shipment, customs duties, and taxes for two payloaders from Japan. To secure the loan, Bautista executed a promissory note and a chattel mortgage over the payloaders on June 20, 1972. The contract stipulated that the payloaders would be delivered to Bunyi for safekeeping upon their release from customs. Bautista defaulted on the loan and failed to deliver the payloaders. Consequently, Bunyi filed a replevin action against Bautista and a “John Doe.” The payloaders were seized from a customs bonded warehouse operated by Rafael M. Sumadchat.
Petitioner Juan V. Sabinosa appeared as the “John Doe,” claiming ownership of the payloaders based on an affidavit from Bautista. However, Bautista later executed a retracting affidavit, reasserting his ownership and the mortgage to Bunyi. The trial court also found that Sabinosa had executed a deed of absolute sale of the payloaders to Rafael M. Sumadchat even before the replevin suit was filed, despite Sabinosa’s answer claiming to be the “real owner-consignee.”
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s decision declaring respondent Bunyi entitled to possession of the payloaders and holding Bautista liable for the loan, despite Sabinosa’s claim of ownership.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic centered on the preponderance of evidence and Sabinosa’s lack of legal standing. The trial court correctly found Bautista to be the owner of the payloaders based on evidence of his acquisition and receipt of the units. The chattel mortgage, though unrecorded, was a valid innominate contract analogous to a chattel mortgage, entitling Bunyi to possession upon Bautista’s default.
Crucially, Sabinosa’s claim was fatally undermined by his own inconsistencies and actions. His assertion of ownership was contradicted by his prior deed of absolute sale to Sumadchat, which divested him of any interest. The Court found his behavior and the purported sale unnatural, suggesting a scheme to place the assets beyond Bunyi’s reach. Since Sabinosa was no longer the owner, he lacked the legal personality to contest the mortgagee’s right to the chattels. That prerogative belonged to Sumadchat, who never intervened. The findings of fact by the lower courts were conclusive, and no compelling reason existed to overturn them. Thus, Bunyi’s right to possession, derived from his contract with the proven owner Bautista, was upheld.