Petitioner
Philippine National Bank
Respondent
Noah'S Ark Sugar Refinery
Citation
G.R. No. 107243
Court
Supreme Court
Division
Second Division
Ponente
Campos, J.
Decided
September 1, 1993

Summary

PNB sought specific performance for delivery of sugar covered by warehouse receipts used as loan collateral. Noah's Ark refused delivery claiming retention of ownership due to non-payment by original buyers. The Regional Trial Court initially denied summary judgment, but the Court of Appeals reversed via certiorari, finding no genuine factual issues and ordering summary judgment for PNB based on negotiable instruments law. The trial judge then defied the appellate directive and dismissed PNB's case. The Supreme Court reversed, emphasizing that final appellate judgments are immutable and binding on trial courts. The case establishes that good faith purchasers of negotiable warehouse receipts acquire valid title despite fraud or breach by prior parties, and that trial courts cannot disregard clear appellate mandates.

Statutes applied

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By the Intellegal Editorial Board · September 1, 1993

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