Professional Documents
Culture Documents
MARANON
FACTS:
PNB contended that it is a mortgagee in good faith and for value and
that its mortgage lien on the property was registered thus valid and
binding against the whole world.
The RTC ruled in favor of Spouses Maraon on the ground that the
deed of sale was falsified and forged the signature of the true owner
of the subject land. Hence, the sale is null and void as such it did not
transfer any right or title in law. The case was not elevated for an
appeal of the decision.
ISSUE:
RULING:
NO. The Court ruled Spouses Maranon has the right to the rents on the
foreclosed property because the rent is a civil fruit that belongs to the
owner of the property producing it by right of accession.
In Castro, Jr. v. CA, the Court explained that Article 2127 is predicated
on the presumption that the ownership of accessions and accessories
also belongs to the mortgagor as the owner of the principal.
In this case, the rightful recipient of the disputed rent should be the
owner of the lot at the time the rent accrued. It is beyond question
that spouses Maranon never lost ownership over the subject lot, and
that technically, there is no juridical tie created by a valid mortgage
contract that binds PNB to the subject lot because the mortgagors
Montealegre were not the true owners which the rule that
improvements shall follow the principal in a mortgage under Article
2127 of the Civil Code does not apply under the premises.
Thus, PNBs claim for the rents paid by the tenants has no basis.