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Property Dispute: Sampaguita Wins

This case involved a dispute over ownership of glass and wooden jalousies installed in a building. Sampaguita Pictures leased space to Capitol, and agreed any improvements Capitol made would belong to Sampaguita. Capitol purchased the jalousies from Jalwindor on credit but did not pay. When Capitol also failed to pay rent, Sampaguita took possession. However, the sheriff later seized the jalousies to satisfy Jalwindor's claim against Capitol. The Supreme Court ruled the jalousies belonged to Sampaguita, not Capitol, as ownership transferred when installed despite nonpayment. The sheriff's sale was invalid as the jalousies were not Capitol's property. Samp

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159 views2 pages

Property Dispute: Sampaguita Wins

This case involved a dispute over ownership of glass and wooden jalousies installed in a building. Sampaguita Pictures leased space to Capitol, and agreed any improvements Capitol made would belong to Sampaguita. Capitol purchased the jalousies from Jalwindor on credit but did not pay. When Capitol also failed to pay rent, Sampaguita took possession. However, the sheriff later seized the jalousies to satisfy Jalwindor's claim against Capitol. The Supreme Court ruled the jalousies belonged to Sampaguita, not Capitol, as ownership transferred when installed despite nonpayment. The sheriff's sale was invalid as the jalousies were not Capitol's property. Samp

Uploaded by

Shally Lao-un
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Sampaguita Pictures, Inc. vs.

Jalwindor Manufacturers, Inc


G.R. No. L-43059
October 11, 1979
J. De Castro

FACTS:

Both the plaintiff-appellant Sampaguita Pictures Inc. (Sampaguita) and defendant-appellee


Jalwindor Manufacturers Inc. (Jalwindor) were domestic corporations duly organized under the
Philippine laws. Sampaguita leased to Capitol “300” Inc. (Capitol) the roof deck of its building with
the agreement that all permanent improvements Capitol will make on said property shall belong to
Sampaguita without any part on the latter to reimburse Capitol for the expenses of said
improvements. Shortly, Capitol purchased on credit from Jalwindor glass and wooden jalousies,
which the latter itself delivered and installed in the leased premises, replacing the existing
windows.

On June 1, 1964, Jalwindor filed with the CFI an action for collection of a sum of money with a
petition for preliminary attachment against Capitol for its failure to pay its purchases. Later,
Jalwindor and Capitol submitted to the trial court a Compromised Agreement wherein Capitol
acknowledged its indebtedness of P9,531.09, payable in monthly installments of at least P300.00 a
month beginning December 15,1964 and that all the materials that Capitol purchased will be
considered as security for such undertaking. Meanwhile, Sampaguita filed a complaint for ejectment
and for collection of a sum of money against Capitol for the latter’s failure to pay rentals from
March 1964 to April 1965, and the City Court of Quezon City ordered Capitol on June 8, 1965 to
vacate the premises and to pay Sampaguita.

On the other hand, Capitol likewise failed to comply with the terms of the Compromise Agreement,
and on July 31, 1966, the Sheriff of Quezon City made levy on the glass and wooden jalousies.
Sampaguita filed a third-party claim alleging that it is the owner of said materials and not Capitol,
but Jalwindor filed an idemnity bond in favor of the Sheriff and the items were sold at public
auction on August 30, 1966, with Jalwindor as the highest bidder for P6,000.00. Sampaguita filed
with the CFI of Rizal, Quezon City an action to nullify the Sheriff's sale and for an injunction to
prevent Jalwindor from detaching the glass and wooden jalousies. Jalwindor was ordered to
maintain the status quo pending final determination of the case, and on October 20, 1967, the lower
court dismissed the complaint and ordered Sampaguita to pay Jalwindor the amount of P500.00 as
attorney's fees.

ISSUE:

Whether or not there was a delivery made and, therefore, a transfer of ownership of the thing sold?

RULING:

YES. The Supreme Court reversed the decision of the lower court declaring Sampaguita as declared
the lawful owner of the disputed glass and wooden jalousies, permanently enjoining Jalwindor from
detaching said items from the roof deck of the Sampaguita Pictures Building, and ordered Jalwindor
to pay Sampaguita the sum of P1,000.00 for and as attorney's fees.

When a property levied upon by the sheriff pursuant to a writ of execution is claimed by a third
person in a sworn statement of ownership thereof, as prescribed by the rules, an entirely different
matter calling for a new adjudication arises. The items in question were illegally levied upon since
they do not belong to the judgment debtor. The power of the Court in execution of judgment
extends only to properties unquestionably belonging to the judgment debtor. The fact that Capitol
failed to pay Jalwindor the purchase price of the items levied upon did not prevent the transfer of
ownership to Capitol and, later, to Sampaguita by virtue of the agreement in their lease contract.
Therefore, the complaint of Sampaguita to nullify the Sheriff's sale is well founded, and should
prosper.

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