Tuesday, January 22, 2019

Case Digest: Villasi vs. Garcia G.R. No. 190106 January 15, 2014


Facts:
Magdalena Villasi won in a case against Fil-Garcia Construction, Inc. (FGCI). A Writ of Execution having been issued in favor of Villasi, the sheriff levied on a building which was built on a lot registered in the names of spouses Filomeno Garcia and Ermelinda Halili-Garcia. The Spouses Garcia filed an Affidavit of Third Party Claim and a Motion to Set Aside Notice of Sale on Execution, claiming ownership of the land and the building which they merely contracted with FGCI to construct and which was mistakenly assessed by the City Assessor in the name of FGCI. The RTC then issued an Order directing the Sheriff to hold in abeyance the conduct of the sale on execution.

Issue:
Whether or not the Sale on Execution of the buildings levied upon must be suspended and held in abeyance on the basis of the respondents' affidavit of third-party claim.

Ruling:
The Court ruled that Spouses Garcia failed to present sufficient evidence proving ownership of the building named under FGCI. The doctrine that accessory follows the principal is inapplicable in this case “where there is a clear and convincing evidence to prove that the principal and the accessory are not owned by one and the same person or entity”. Thus, the Court directed the Deputy Sheriff to proceed with the conduct of the sale on execution of the levied building in favour of Villasi.

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