Standard Oil Co. of New York v. Jaramillo
REITERATIONFacts
The Antecedents: Gervasia de la Rosa, Vda. de Vera, leased a parcel of land in Manila and owned the house built thereon. She executed a document purporting to be a chattel mortgage in favor of the Standard Oil Company of New York, conveying her leasehold interest in the land and the building as security. Procedural History: The document was presented to Joaquin Jaramillo, the register of deeds of the City of Manila, for registration. The respondent refused registration, opining that the interest mortgaged was not personal property under the Chattel Mortgage Law. The Petition: The Standard Oil Company of New York filed an original petition for a peremptory writ of mandamus to compel the respondent register of deeds to record the chattel mortgage.
Issue(s)
Whether the register of deeds has the authority to determine the nature of the property sought to be registered as a chattel mortgage. Whether the duty of the register of deeds in recording chattel mortgages is ministerial or judicial.
Ruling
The demurrer is overruled. The register of deeds is ordered to accept the proper fee and record the instrument as a chattel mortgage. If no sufficient answer is interposed within five days, the writ of mandamus shall issue.
Ratio Decidendi
On the authority of the register of deeds to determine the nature of the property: The Court held that the position of the respondent register of deeds was untenable. The duties of a register of deeds concerning the registration of chattel mortgages are purely ministerial. No law confers upon the register of deeds any judicial or quasi-judicial power to determine the nature of a document presented for registration as a chattel mortgage. The register of deeds has no authority to pass upon the "qualification" of a chattel mortgage, which is a matter for the courts to decide. The efficacy of registration lies in its function as constructive notice, not in the register's assessment of the property's character. On the ministerial nature of the register's duty: The Court affirmed that the duties of the register of deeds in respect to the registration of chattel mortgages are ministerial only. Section 198 of the Administrative Code, which incorporates provisions from the Chattel Mortgage Law, does not grant the register of deeds any authority to pass upon the character of the property sought to be encumbered. While the effectiveness of a chattel mortgage over real property might be questioned in court, this does not empower the register of deeds to refuse registration based on his own determination of the property's classification. The register's role is to record, not to adjudicate.
Main Doctrine
The duty of a register of deeds to record a chattel mortgage is purely ministerial; he has no authority to pass upon the nature of the property sought to be mortgaged, as this determination is for the courts.