Mamsar Enterprises Agro-Industrial Corp. v. Varley Trading, Inc.
REITERATIONFacts
The Antecedents: Respondent Varley Trading, Inc. sold heavy equipment to petitioner Mamsar Enterprises Agro-Industrial Corporation for logging operations. In September 1988, respondent's COO, Paul Nesbitt, purchased a D6 direct drive bulldozer and sent it with a team headed by Francisco Falcasantos. Due to insufficient capacity, Falcasantos requested another bulldozer. In December 1988, Nesbitt shipped a DC6 Powershift bulldozer to Vicente Tadle, who then sent it to Bayug. In February 1989, Nesbitt died and was succeeded by Teotimo Santos. On February 19, 1990, Tadle, under Santos' orders, went to Alicia, Zamboanga del Sur to recover the second bulldozer from Falcasantos and Benjamin Perno. Tadle and his team obtained what they believed was the second bulldozer. While in transit, they were intercepted by the Chief of Police, P/Lt. Catalino Milla, who took custody of the bulldozer upon Perno's representation. Procedural History: On February 26, 1990, respondent filed a complaint for damages with a prayer for a writ of replevin against petitioner and its agents (Falcasantos, Perno, and Manuel Dasmariñas) before the RTC of Iligan City. Respondent alleged that petitioner's agents transferred the bulldozer from respondent's site to their own project and unlawfully used it for their benefit. Respondent also claimed the bulldozer was seized by P/Lt. Milla without a court order. On February 27, 1990, the trial court issued the writ of replevin. Petitioner filed an answer denying the allegations and claiming ownership of the bulldozer, presenting a deed of absolute sale. The trial court ruled in favor of respondent, absolving the agents as mere employees. The Court of Appeals affirmed the RTC decision. The Petition: Petitioner filed a petition for review on certiorari, arguing that the Court of Appeals erred in affirming the trial court's decision, particularly in its appreciation of crucial evidence, and that the case hinges exclusively on questions of fact.
Issue(s)
Whether the trial court correctly found that the bulldozer in question belonged to respondent and not to petitioner, specifically regarding the alleged tampering of the serial number. Whether the trial court correctly computed the rental income due from the use of the bulldozer, assuming it belonged to the respondent.
Ruling
The Supreme Court dismissed the petition and affirmed the decision of the Court of Appeals. Costs were against the petitioner.
Ratio Decidendi
On the ownership of the bulldozer and tampering of serial number: The Court held that the issues of ownership and the alleged tampering of the serial number were questions of fact. The trial court's findings were based on evidence including testimony from respondent's witness, photographs, and stencils presented by both parties. The trial court found the serial numbers on the chassis to be "crude irregular, misshapen and misaligned" and bearing clear signs of tampering. The Supreme Court reiterated its doctrine that it is not a trier of facts and will not disturb the findings of the lower courts unless specific exceptions apply. None of these exceptions were found to be present in this case, and no grave abuse of discretion was committed by the trial court in its appreciation of the evidence. Therefore, the finding that the bulldozer belonged to the respondent and that its serial number was tampered with was upheld. On the computation of rental income: The Court found that the computation of rental income was also a question of fact. The award of P72,000 per month was based on an hourly rate of P450, which was attested to by witnesses from both the respondent and the petitioner. Since this was a factual determination supported by evidence presented by both parties, and no exceptions to the rule against reviewing factual findings were met, the Court affirmed the computation. The petitioner's contention that the bulldozer was in poor condition was a factual argument that was presumably considered and rejected by the lower courts.
Main Doctrine
The Supreme Court is not a trier of facts and will not disturb the findings of the Court of Appeals and the trial court unless there are exceptions such as grave abuse of discretion, misapprehension of facts, or conflicting findings.