Philippine National Bank v. Se
G.R. No. 119231 (April 18, 1996)
Facts:
The case revolves around a dispute between the Philippine National Bank (PNB) and Noahas Ark Sugar Refinery regarding the ownership and storage fees of sugar stocks covered by five Warehouse Receipts (quedans). The Warehouse Receipts were issued by Noahas Ark Sugar Refinery for sugar deposited by various parties, which were subsequently negotiated to Luis T. Ramos and Cresencia K. Zoleta as collateral for loans from PNB. When Ramos and Zoleta defaulted on their loans, PNB demanded the delivery of the sugar stocks from Noahas Ark, which refused, claiming ownership of the sugar.
PNB filed a complaint for specific performance and damages against Noahas Ark and its officers. The Regional Trial Court (RTC) initially denied PNB's application for a preliminary attachment and later dismissed PNB's complaint for lack of cause of action. PNB appealed to the Court of Appeals, which ruled in favor of PNB, ordering Noahas Ark to deliver the sugar stocks or pay damages. This decision was affirmed by the Supreme Court.
Despite the Supreme Court's ruling, Noahas Ark filed an omnibus motion claiming a warehouseman's lien for storage fees and preservation expenses, which the RTC granted, leading to PNB's petition for certiorari to annul the RTC's orders.
Legal Issues:
- Whether the RTC had the authority to grant Noahas Ark's claim for warehouseman's lien after the Supreme Court had already ruled on the ownership of the sugar stocks.
- Whether PNB was obligated to pay storage fees before receiving the sugar stocks.
Arguments:
Petitioner (PNB): PNB argued that it had a right to a writ of execution based on the final and executory decisions of the Court of Appeals and the Supreme Court. PNB contended that the RTC had no jurisdiction to hear Noahas Ark's omnibus motion for a warehouseman's lien since the issue of ownership had already been settled. PNB maintained that the RTC was required to issue a writ of execution to enforce the Supreme Court's decision.
Respondents (Noahas Ark): Noahas Ark contended that they were entitled to enforce their warehouseman's lien for storage fees and preservation expenses before delivering the sugar stocks. They argued that their claim for a lien was valid under the Warehouse Receipts Law and that the RTC's orders were justified as they had not been given the opportunity to present evidence for their claim.
Court's Decision and Legal Reasoning:
The Supreme Court dismissed PNB's petition, affirming the RTC's orders. The Court held that Noahas Ark, having been declared a warehouseman, retained the right to enforce its warehouseman's lien for storage fees and preservation expenses. The Court emphasized that the lien is possessory in nature, meaning that Noahas Ark could refuse to deliver the sugar stocks until the lien was satisfied.
The Court clarified that the previous rulings did not preclude Noahas Ark from asserting its right to a lien, as the issue of ownership had been resolved separately from the issue of storage fees. The Court also noted that the terms of the Warehouse Receipts explicitly provided for the imposition of storage fees after a certain period, which further supported Noahas Ark's claim.
The Court concluded that PNB, as the endorsee of the quedans, was bound by the terms of the Warehouse Receipts, including the obligation to pay storage fees. The Court reiterated that obligations arising from contracts must be complied with in good faith, and PNB could not claim the sugar stocks without satisfying the lien.
Significant Legal Principles Established:
- A warehouseman's lien is a possessory right that allows the warehouseman to retain possession of goods until payment for storage and preservation fees is made.
- The right to enforce a warehouseman's lien is not extinguished by a prior determination of ownership, as the issues of ownership and lien can be treated separately.
- Parties are bound by the terms of contracts, including warehouse receipts, which stipulate obligations such as the payment of storage fees.