Sps. Moises v. Pilhino Sales Corporation

Summary

Spouses Moises and Clemencia Andrada sought damages from Pilhino Sales Corporation under the abuse of rights doctrine, claiming Pilhino acted in bad faith when it levied execution on their Hino truck. The truck was originally owned by Jose Andrada Jr., who sold it to Moises to allegedly evade creditors. When Pilhino executed its judgment against Jose, it seized the truck, but could not obtain title due to the sale to Moises. Pilhino then filed an action to annul the sale as simulated. The Supreme Court denied the petition, finding that questions of fact cannot be reviewed under Rule 45, and that the Court of Appeals correctly determined Pilhino acted in good faith. The case demonstrates the restrictive nature of Supreme Court review under Rule 45 and the stringent requirements for establishing abuse of rights claims under Articles 19 and 21 of the Civil Code.