Lex Rex Ph

Standard Oil vs. Jaramillo Digest

“A ‘Specie of Notice'”

COMPLETE NAMES OF PARTIES: Standard Oil of New York, petitionerVs. Joaquin Jaramillo, register of deeds of Manila

NUMBER AND DATE: GR 20329; Mar 16, 1923

MY UNIQUE NAME OF THIS CASE: Mr. ROD, don’t act as judge.

LESSONS RELATED TO SUBJECT/TEACHER’S EMPHASIZED POINTS: Famous quote from this case: “It is a familiar phenomenon where things that are considered personal property, are classified as real property for purposes of taxation.”

THESIS STATEMENT: Standard Oil Co. FILED a case against ROD of Manilato register the instruments in the records of Chattel Mortgageon the grounds that mortgaged house by a tenant is personal property.

FACTS

  • De Vera was lessee/tenant of land in Manila, and owner of house of strong materials upon it. Executed chattel mortgage upon the house conveying to Standard Oil leasehold interest/rights in said lot and building.
  • Standard Oil (p) then delivered to Jaranillo (r) for the purpose of recording in the book of record of chattel mortgages.
  • Jaranillo refused because he is of the opinion that the house in question was not a chattel mortgage.
PLAINTIFF OIL CO.DEFENDANT ROD Jaranillo
ROD to record the chattel mortgage by De Vera in proper document in favor of Standard OilSaid instrument is not chattel mortgage because the mortgage is not personal property within the meaning of Chattel Mortgage Law.

SC: This position is untenable.

Who filed to SC: Standard Oil Co

ISSUE 1: Is the act of the ROD Jaranillo tenable/valid/lawful? No.

  1. His duty is purely ministerial in character: that is to accept the fee and record the instrument.
  2. No law confers him any judicial or quasi-judicial power to determine the nature of any document of which registration is sought as chattel mortgage.
  3. He must leave the effects of registration and determination to the court if questions arise.

ISSUE 2: What is the purpose or effect of recording an instrument in a chattel mortgage? Constructive Notice

  • It serves as a constructive notice of the existence of the contract.
  • Must the legal effects of the contract be discovered in the instrument iteself along with the notice? Yes.
  • Does registration adds anything to the document or affects anybody’s rights? No. It only serves as a source of title and a species of notice.

What should the register of deeds do? Register (LOL)

  • Jaranillo should accept the document of Standard Oil Co and register it.

Is registering a “house of strong materials” in Chattel Mortgage a futile act?

  • Raising that question based on the ruling in Leung Yee v. Strong is not decisive of the question in this case.

SUPREME COURT RULING: The demurrer of ROD is OVERRULED, unless within 5 days, ROD shall interpose a sufficient answer to the petition, the writ of mandamus will be issued as prayed.

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