Manuel Crame Sy Panco v. Ricardo Gonzaga et al.
Supreme Court Bill No. 10 Phil. 646
**Facts:**
Manuel Crame Sy Panco (Plaintiff) instituted an action against Alejo Lanzon in the Justice of the Peace Court of Victorias, Occidental Negros, for the recovery of P300.42. Plaintiff obtained a preliminary attachment of Lanzon’s property, which was levied on three of his carabaos. This attachment was released when the defendants in this case posted a bond of P500. The bond stipulated that the defendants would either return the carabaos for enforcement should judgment favor the plaintiff or, if unable to do so, pay the carabaos’ value.
Lanzon was ultimately ordered to pay the claimed amount. An execution writ was issued but wasn’t enforced as Lanzon had no property subject to execution, and the carabaos were not delivered, apparently having died of a prevalent disease. Plaintiff sought enforcement of the bond up to P300.42 plus interest, claiming Lanzon’s inability to fulfill the judgment.
The defendants, Gonzaga et al., alleged that the carabaos died due to a prevalent disease, presenting two corroborating witnesses without contradiction. The lower court, however, did not accept that all three carabaos had died, although the judgment did not clearly justify this skepticism. The death of the carabaos was fortuitous and without defendants’ fault, extinguishing their bond obligations per Civil Code Article 1182 and 1105.
Moreover, defendants argued that their bond ensured the return of the carabaos, not payment of Lanzon’s debt. Defendants also agreed to pay P57.47 for costs in the original lawsuit against Lanzon, which was included in their bond.
**Issues:**
1. Was the trial court correct in not accepting the uncontradicted testimony that all three carabaos had died of a prevalent disease?
2. Does the death of the carabaos exempt the defendants from returning them or paying their value under the bond terms?
3. Are the defendants liable for Lanzon’s debt notwithstanding the bond’s limited liability for the carabaos?
4. Should the defendants pay for the costs of P57.47 from Lanzon’s original action?
**Court’s Decision:**
1. The Supreme Court, noting the uncontradicted and sufficient corroborative evidence provided by the defense witnesses, found it unreasonable for the trial court to reject their testimony.
2. The Court ruled that the defendants were exempt from both returning the carabaos and paying their value as their death was fortuitous. Extinction of bond obligation is consistent with Articles 1182 and 1105 of the Civil Code, which releases obligated individuals from accountability in fortuitous events unless explicitly agreed otherwise.
3. Since the defendants’ bond was limited to returning the carabaos or paying their value, and the carabaos’ value was not established in court, the defendants couldn’t be compelled to pay the P300.42 debt of Lanzon. Section 440 of the Code of Civil Procedure explicitly limited liability to the property or its value, which was not determined.
4. The Supreme Court upheld the portion of the judgment regarding the P57.47 costs in Lanzon’s original action because the defendants had acknowledged this liability.
**Doctrine:**
1. A bond obligation is extinguished if the property subject to the bond perishes through no fault of the obligor, following Articles 1182 and 1105 of the Civil Code.
2. Under Section 440 of the Code of Civil Procedure, bond liability is limited to the return of attached property or its value, not exceeding the bond amount.
**Class Notes:**
– **Key Elements:**
– Preliminary Attachment
– Bond Obligations
– Fortuitous Event Doctrine
– Civil Code Article 1182 & 1105
– Code of Civil Procedure Sec. 440
– **Simplified Principles:**
– Bonds only cover the attached property’s return or its value.
– Obligations tied to specific property releases are void if the property unavoidably perishes.
– Clear, uncontradicted witness testimony must generally be accepted as true.
**Historical Background:**
The case unfolds in the early 20th century Philippine legal environment where property attachment and bond obligations were critical in civil litigations. Lanzon’s debt and subsequent loss of his carabaos within a disease-prevalent locale showcase the interface between local economic realities and formal legal obligations. The ruling solidified protections for obligors under fortuitous circumstances, shaping future interpretations of bond responsibilities in Philippine legal jurisprudence.
Leave a Reply