Friday, January 19, 2024

Case Digest: McMicking vs. Banco Espanol, G.R. No. 5029

 

McMicking vs. Banco Espanol, 13 Phil 429, G.R. No. 5029, April 1, 1909

Subject: Transportation Law


FACTS

In 1907, Sanchez and Cue Suan owned the Hock-Tay steamship. They borrowed P3,000 from El Banco Español-Filipino and provided a chattel mortgage as security. The mortgage was recorded in the port's collector of customs and register of property. In October, El Banco Español-Filipino delivered the mortgage to Manila's sheriff, requesting the ship's sale. The sheriff informed the mortgagors of the request and the ship would be sold in accordance with the law. The sale was scheduled for October 27th, and the steamer was sold to the highest bidder for P30,000. The transaction was documented in various records.

ISSUE

Whether or not appellant has liens existing in this case.

RULING

Yes, the appellant has existing liens.

Under Article 580 of the Code of Commerce, the wages of the crew and expenses incurred for the ship during the last voyage have a preference over the claim of a mortgagee.

In this case, this reference is known as a legal lien and takes priority over a lien created by giving the ship as security for money borrowed. The sale of a ship under a mortgage does not affect the right of prior lien holders, and their remedies lie in foreclosing their liens against the ship itself.


 

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