SUPERLINES TRANSPORTATION COMPANY, INC.

,
petitioner,
vs.
PHILIPPINE NATIONAL CONSTRUCTION
COMPANY and PEDRO BALUBAL, respondents.
G.R. No. 169596. | March 28, 2007.
J. Carpio-Morales

Digest Author: Jude Fanila

Topic: I. General Principles – J. Doctrine of non-interference or doctrine of Judicial Stability

Case Summary: Petitioner is a transportation company who owned a bus that crashed into respondent’s
radio room. Respondent, upon verbal orders of police officers towed and impounded the subject bus.
Petitioner filed for a writ of replevin to recover possession of the bus. SC ruled in their favor, finding that
while generally, properties held as evidence in a criminal case cannot be replevied, the rule only applies
in cases where the property is lawfully held i.e. in custodia legis if it not lawfully held, then it cannot be
considered as in the custody of the law and therefore can be the subject of a writ of replevin.

Petitioners: SUPERLINES TRANSPORTATION COMPANY, INC.,

Respondents: PHILIPPINE NATIONAL CONSTRUCTION
COMPANY and PEDRO BALUBAL

Doctrines Involved: The doctrine of judicial stability or non-interference in the regular orders or
judgments of a co-equal court is an elementary principle in the administration of justice: no court can
interfere by injunction with the judgments or orders of another court of concurrent jurisdiction having
the power to grant the relief sought by the injunction.

The rationale for the rule is founded on the concept of jurisdiction: a court that acquires jurisdiction over
the case and renders judgment therein has jurisdiction over its judgment, to the exclusion of all other
coordinate courts, for its execution and over all its incidents, and to control, in furtherance of
justice, the conduct of ministerial officers acting in connection with this judgment.

(Honestly parang walang related sa judicial stability sa case, at most it cites the previous case, Bagalihog
which had a similar ratio that properties that were held in custodia legis as evidence in a criminal case
cannot be subject to a writ of replevin. So I guess non-interference because co-equal courts cant issue a
replevin/similar reliefs if property is seized pursuant to judicial orders of a co-equal court?)

FACTS:
1. Current case is petition for review of Sept. 6 2005 CA Decision which dismissed petitioners
appeal of the RTC Case.
2. Petitioner, Superlines is a corporation engaged in the business of providing public transportation.
3. Dec. 13 1990 – One of petitioner’s buses, traveling north along the Alabang northbound exit lane,
swerved and crashed into the radio room of respondent, PNCC.
a. Upon investigation by PNCC’s tollway patrol and respondent Balubal (head of traffic
control and security department of the South Luzon tollway) the bus was turned over to
the Alabang Traffic Bureau for a separate investigation.
i. Bus was towed and stored at the PNCC patrol compound upon request of traffic
investigator Pat. Cesar Lopera.
 4. Subsequently, petitioner made several requests with the PNCC to release the bus, but respondent
Balubal denied requests. Petitioner committed to repair the damaged radio room but respondent
Balubal demanded different terms:
a. P40,000 or collateral with the same value, representing PNCC’s estimate of the cost of
reconstruction of the radio room.
i. Petitioner estimated damage to amount only to P10,000.
Start of Procedural History
5. This dispute led petitioner to file a complaint for recovery of personal property (replevin) with
damages against the respondents before the RTC of Quezon praying for the following reliefs:
a. adjudging that plaintiff has the right to the possession of subject personal property and
awarding the material possession of said property to plaintiff as the sole and absolute
owner thereof; ordering defendants jointly and severally to pay the plaintiff the
following:
i. P500k in unrealized income computed from the date of the filing of the instant
complaint
ii. P7,500 daily until subject bus has been returned
iii. P100k for attorney's fees
iv. P20,000 as legal fees + costs of suit
6. However, petitioner was unable to put up bond for the issuance of the writ of replevin, therefore
opted to wait for the court’s final judgment.
7. Respondents, by way of counterclaim prayed for: P40k in actual damages, P50k in exemplary
damages, P130k in legal and attorney’s fees.
a. Claimed that they merely towed the bus to the PNCC compound for safekeeping,
pursuant to orders of police authorities. Balubal did not return bus due to absence of order
from police to return the same. Petitioner also failed to present certificate of registration
and official receipt of payment to establish ownership of t he bus; that the bus that was
the subject of the complaint was different from the bus that was involved in the radio
room incident.
8. Dec. 9 1997 – RTC dismissed petitioner’s complaint, ordered them to pay respondent PNCC
P40,320 in actual damages.
9. CA – on appeal, the CA held that the storage of the bus for safekeeping purposes was in the
nature of a deposit, therefore custody or authority over it remained with the officer who ordered
its storage, Lopera. Absent any order from him, PNCC could not release the bus.
a. CA ruled that case should have been brought against police authorities, not the
respondent.

ARGUMENTS BEFORE THE SUPREME COURT:

 Petitioner’s Argument related to Doctrine: Case didn’t specify, but argument appears to be same
as the RTC argument i.e. that petitioner was the rightful owner of the bus, thus entitled to its
possession.
 Respondent’s Argument related to Doctrine: Current petition raises only questions of fact, thus
suffering from a defect due to its failure to include “such material portions of the record as would
support the petition” as required by Sec. 4, Rule 45 of the Rules of Court 1

1
SEC. 4. Contents of petition.—The petition shall be filed in eighteen (18) copies, with the original copy intended for the court
being indicated as such by the petitioner, and shall (a) state the full name of the appealing party as the petitioner and the adverse
party as respondent, without impleading the lower courts or judges thereof either as petitioner or respondents; (b) indicate the
material dates showing when notice of the judgment or final order or resolution subject thereof was received when a motion for
new trial or reconsideration, if any, was filed and when notice of the denial thereof was received; (c) set forth concisely a
statement of the matters involved, and the reasons or arguments relied on for the allowance of the petition; (d) be accompanied by
a clearly legible duplicate original, or a certified true copy of the judgment or final order or resolution certified by the clerk of
ISSUES + HELD:
1. W/N petition should be dismissed for failure to comply with Sec. 4, Rule 45 of the ROC? –
NO
a. Though the petition failed to comply with the requirements of Rule 45 regarding the
contents of and the documents which should accompany the petition the court exercises
its equity jurisdiction which provides that procedural lapses may be disregarded so that a
case may be resolved on its merits.
i. As held in Durban Apartments Corporations v. Catacutan – The dismissal of
cases on purely technical grounds is frowned upon if they tend to frustrate
substantial justice i.e. allowing parties opportunity to fully ventilate their causes
and defenses. As a rule, rules of procedure are mere tools designed to expedite
the resolution of cases/other matters pending before the courts, therefore a strict
and rigid application that tend to frustrate rather than promote justice must be
avoided.
2. W/N SC can pass upon questions of fact raised before the lower courts? – YES
a. As a general rule, the SC deigns to rule on questions of fact, however it may at times
undertake a re-examination of the evidence presented by the parties in recognized
exceptions, which were enumerated in Insular life Assurance Company, Ltd. v. CA as
follows:
i. 1) when the findings are grounded entirely on speculation, surmises or
conjectures; (2) when the inference made is manifestly mistaken, absurd or
impossible; (3) when there is grave abuse of discretion; (4) when the judgment is
based on a misapprehension of facts; (5) when the findings of facts are
conflicting; (6) when in making its findings the Court of Appeals went beyond
the issues of the case, or its findings are contrary to the admissions of both the
appellant and the appellee; (7) when the findings are contrary to the trial court;
(8) when the findings are conclusions without citation of specific evidence on
which they are based; (9) when the facts set forth in the petition as well as in the
petitioner’s main and reply briefs are not disputed by the respondent; (10) when
the findings of fact are premised on the supposed absence of evidence and
contradicted by the evidence on record; and (11) when the Court of Appeals
manifestly overlooked certain relevant facts not disputed by the parties, which, if
properly considered, would justify a different conclusion.
ii. In the present case, #11 applies (Discussed in next issue)

3. W/N the owner of personal property may initiate an action for replevin against a depositary
and recover damages for illegal restraint? – YES
a. In a complaint for replevin, the claimant must convincingly show that he is either the
owner or clearly entitled to the possession of the object sought to be recovered. In the
present case, ownership of petitioner already admitted by the respondent, only remaining
issue is w/n there was wrongful detainer pursuant to the orders of Lopera.

court of the court a quo and the requisite number of plain copies thereof, and such material portions of the record as would
support the petition; and (e) contain a sworn certification against forum shopping as provided in the last paragraph of section 2,
Rule 42.
 i. SC notes that detention was not due for tax assessments, fines, or seized under
writs of execution or preliminary attachment or otherwise placed under custodia
legis.
b. CA held that now law authorizing the impounding of a vehicle involved in an accident by
the police authorities, similarly no law making the impounding of vehicles involved in
accidents illegal. According to CA, SC is of the view that no clear-cut policy or rule on
the matter of impounding vehicles involved in accidents.
i. Relied on ruling in Victory Liner, Inc. v Bellosillo to justify impounding.
c. SC – overturns CA ruling, Art. III – Sec. 2 of the Constitution explicitly grants the right
against unreasonable search and seizures. Seizure and impounding of the vehicle without
any reference to enabling law clearly violates this right.
i. Reliance on Victory Liner misplaced, as there court declined to rule on the
legality of the impoundment of the vehicle as it was an administrative case. SC’s
statement there about lack of clear-cut policy referred to the practice of trial court
judges issuing orders for the impounding of vehicles involved in accidents, not of
search and seizures implemented without color of legality such as in the present
case. (Bus was seized only upon verbal order of Lopera).
ii. The fact that the bus driver was criminally charged for reckless imprudence
resulting in damage to property irrelevant. As held in Bagalihog v. Fernandez
1. While generally, properties held as evidence in a criminal case cannot be
replevied, the rule only applies in cases where the property is lawfully
held i.e. in custodia legis 2 if it not lawfully held, then it cannot be
considered as in the custody of the law and therefore can be the subject
of a writ of replevin.
iii. SC does not rule on claims for damages, as Lopera and other police officers not
impleaded in the case.

RULING:

WHEREFORE, the assailed Court of Appeals Decision is REVERSED and SET ASIDE.
The prayer of petitioner, Superlines Transportation Company, Inc., for recovery of possession of
personal property is GRANTED.
The records of the case are REMANDED to the court of origin, the Regional Trial Court, Branch
62, Gumaca, Quezon, which is DIRECTED to REINSTATE petitioner’s complaint to its docket
if petitioner is still interested to pursue its claim for damages and to act in accordance with the
foregoing pronouncement of the Court.
SO ORDERED.

2
A thing is in cusodia legis if it has been shown that it has and is subjected to official custody of a judicial executive
officer in pursuance of his execution of a legal writ