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PNB vs. Sayo

This case involved warehouse receipts issued by Noah's Ark covering sugar deposits owned by various entities. Four receipts were later negotiated to Luis Ramos and Cresencia Zoleta, who used them to secure a loan from PNB. When the loan was not repaid, PNB demanded the sugar but Noah's Ark refused, claiming ownership. The Supreme Court ruled that the subsequent endorsers of the receipts acquired ownership of the sugar, as the initial sale transferring ownership was valid. Noah's Ark therefore had no legal right to the sugar and was ordered to deliver it to PNB.

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Grace Ann Tamboon
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50 views2 pages

PNB vs. Sayo

This case involved warehouse receipts issued by Noah's Ark covering sugar deposits owned by various entities. Four receipts were later negotiated to Luis Ramos and Cresencia Zoleta, who used them to secure a loan from PNB. When the loan was not repaid, PNB demanded the sugar but Noah's Ark refused, claiming ownership. The Supreme Court ruled that the subsequent endorsers of the receipts acquired ownership of the sugar, as the initial sale transferring ownership was valid. Noah's Ark therefore had no legal right to the sugar and was ordered to deliver it to PNB.

Uploaded by

Grace Ann Tamboon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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AUTHORSHIP INFORMATION

Digest Author Grace Ann Tamboon


Topic Warehouse Receipt Law Satisfaction of Lien
CASE INFORMATION
Petitioner(s) Philippine National Bank
Respondent(s) Hon. Marcelino L. Sayo, Jr.
Reference G.R. No. 129918 July 9, 1998
Ponente Villarama, Jr., J.
DOCTRINE(S)

The subsequent endorsers of a warehouse receipt acquire ownership of the goods covered by
the receipt, provided that the initial sale was valid.

CASE SUMMARY

Noah's Ark issued warehouse receipts covering sugar


deposits by Rosa Sy, RNS Merchandising, and St.
Therese Merchandising. Four of these receipts were
subsequently negotiated to Luis Ramos and Cresencia
Zoleta, who used them to secure a loan with PNB.
Pertinent Facts Ramos and Zoleta failed to pay the loan, so PNB
demanded delivery of the sugar deposits covered by
the warehouse receipts. However, Noah's Ark refused,
claiming ownership over the sugar.

Noah's Ark argued that the initial sale of the sugar to


Rosa Sy and Teresita Ng of St. Therese Merchandising
was a simulated sale, and subsequent endorsers did
not acquire ownership of the sugar deposits.

PROCEDURAL HISTORY

RTC RTC Manila denied the writ of attachment.

CA CA ordered RTC to render a summary judgment in


favor of PNB.

Relevant Issue(s) Whether or not the subsequent endorsers of the


warehouse receipts acquired ownership of the sugar
deposits covered by the receipts.

In this case, the Supreme Court ruled that the


subsequent endorsers of the warehouse receipts
acquired ownership of the sugar deposits covered by
Analysis the receipts, and the initial sale of the sugar to Rosa Sy
and Teresita Ng was a valid sale. As such, Noah's Ark
had no legal right to claim ownership over the sugar
deposits, and PNB was entitled to damages. Therefore,
the trial court's decision to dismiss the plaintiff's
complaint and the defendants' counterclaims was
reversed, and Noah's Ark was ordered to deliver the
sugar to PNB.

The Supreme Court ruled that the subsequent


endorsers of the warehouse receipts acquired
ownership of the sugar deposits covered by the
receipts. The court held that the initial sale of the sugar
to Rosa Sy and Teresita Ng was a valid sale, and
Ruling(s) & Rationale subsequent endorsers acquired ownership of the
sugar. The court also held that Noah's Ark had no legal
right to claim ownership over the sugar deposits, and
PNB was entitled to damages. The trial court's decision
to dismiss the plaintiff's complaint and the defendants'
counterclaims was reversed, and Noah's Ark was
ordered to deliver the sugar to PNB.

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