First Nationwide Assurance Corporation v. Court Of Appeals
REITERATIONFacts
The Antecedents: Petitioner First Nationwide Assurance Corporation (FNAC) was the insurer of a 1987 Mitsubishi Pajero, registered to Gerald Brimo, which was carnapped on June 5, 1988. Brimo reported the incident, and the vehicle was placed on the list of carnapped vehicles. Lt. Angelito Tan of the Constabulary Highway Patrol Group (CHPG) received information about the carnapped Pajero. Intervenor Eduardo Conde agreed to buy a Mitsubishi Pajero from Gregorio Elardo through a broker. Conde had the vehicle inspected, including its chassis number and registration papers with the LTO, and by Capt. Alcantara of the CHPG. A deed of sale was executed in favor of Conde on July 28, 1988. On August 4, 1988, Conde was informed that the vehicle was seized in Bacolod on suspicion of being the stolen vehicle. Conde presented the vehicle's papers, and its release was ordered after he signed an undertaking. Conde later had the engine and chassis numbers subjected to macro-etching in Manila, which yielded no findings of tampering, and a certification of "no record" was issued. On August 12, 1988, Elardo was arrested for carnapping. Lt. Tan informed Conde that the vehicle's clearance was irregular due to spurious documentation and that the plate number assigned to Conde's vehicle belonged to another. The LTO certificate of registration was also found to be of dubious origin. On October 28, 1988, a warrant was issued, and the Pajero was again seized for macro-etching. Conde moved to quash the warrant. On November 3, 1988, further macro-etching was conducted in Bacolod, which reportedly found filings on the chassis number, altering the eighth digit from "3" to "5". FNAC indemnified Brimo and was subrogated to his rights. An order for seizure of personal property was issued by the Manila trial court. FNAC intervened in the Bacolod proceedings and filed a replevin case in Manila. Conde filed a complaint in intervention in the Manila trial court, asserting his ownership based on a CHPG clearance. Procedural History: The Regional Trial Court (RTC) of Manila declared FNAC the lawful owner and entitled to possession of the vehicle, dismissing Conde's complaint in intervention. The Court of Appeals (CA) reversed the RTC decision, finding that FNAC failed to prove the identity of the Pajero in question as the one carnapped from Brimo and declared Conde entitled to ownership and possession. FNAC filed a Motion for Reconsideration, which was denied by the CA. The Petition: FNAC filed a Petition for Review with the Supreme Court, assailing the CA's decision and resolution, arguing that the CA erred in ignoring overwhelming evidence of the Pajero's identity and in holding that Conde's evidence rebutted the presumption of regularity of official conduct.
Issue(s)
Whether the Court of Appeals erred in finding that the petitioner failed to prove that the Pajero claimed by intervenor Conde was the same vehicle carnapped from Gerald Brimo. Whether the Court of Appeals erred in holding that the evidence of intervenor Conde rebutted and overcame the presumption of regularity of official conduct.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court of Manila, declaring petitioner First Nationwide Assurance Corporation as the lawful owner of the subject vehicle.
Ratio Decidendi
On the issue of ownership and identity of the vehicle: The Supreme Court found that the Court of Appeals erred in appreciating the evidence. The Court held that the testimony of Sgt. Edmundo Agadulin, who conducted a macro-etching examination, sufficiently established that the Pajero claimed by Conde was the same vehicle carnapped from Brimo. Agadulin found signs of filing and alteration on the eighth digit of the chassis number of Conde's Pajero, which was initially "5" but restored to "3", revealing the original number "L049GV-0034B". This restored number matched the identifying mark of Brimo's stolen vehicle. The Court emphasized that Agadulin, as a police officer with adequate training and experience in macro-etching, is presumed to have regularly performed his duty, and his testimony, in the absence of controverting evidence, is entitled to great weight. Furthermore, the Court noted that the recorded chassis number of Conde's Pajero, "L049GV-0054B," had been assigned to another vehicle, and the sole authorized assembler of Mitsubishi vehicles certified that each chassis number is issued only once. The Court also pointed to other circumstances, such as the plate number assigned to another vehicle and the fraudulent origin of Conde's certificate of registration, which cast doubt on Conde's title. The Court concluded that these documentary exhibits, coupled with Agadulin's testimony, indubitably showed that Conde's purported ownership was a sham and that the Pajero was indeed the carnapped vehicle reported by Brimo. On the presumption of regularity of official conduct: The Supreme Court disagreed with the Court of Appeals' conclusion that Conde's evidence rebutted the presumption of regularity of official conduct. The Court found that the circumstances relied upon by the CA, such as the certification by the Bacolod LTO chief and inspections by Capt. Alcantara, did not prove Conde's claim. The certification merely stated the vehicle was not on the list of stolen vehicles at that time, which was possible because the chassis number had already been tampered with. Neither the LTO nor Capt. Alcantara conducted macro-etching examinations, and Alcantara's credibility was challenged by Lt. Tan. The Court also dismissed the claim of a previous macro-etching examination by two soldiers, as they were not presented as witnesses, and the Motor Vehicle Verification Slip presented only confirmed that the chassis number had no record of being stolen, not that it was untampered. The Court found no basis for the CA's suspicion regarding the motives of Lt. Tan and Sgt. Agadulin, explaining that their refusal to release stencils was justified by protocol and lack of a court order or superior's directive. The CA's implication that tampering occurred during the vehicle's six-day stay in the CHPG compound was deemed speculative, as no evidence of tampering during that period was presented, and the vehicle's registration certificate already indicated a tampered number prior to its seizure.
Main Doctrine
The Supreme Court reversed the Court of Appeals, finding that the evidence, particularly the expert testimony on macro-etching and documentary exhibits, sufficiently established that the vehicle claimed by the intervenor was the same carnapped vehicle, despite the intervenor's claims of good faith purchase and dubious documentation.