B. H. Macke v. Jose Rubert

Summary

This replevin case involved competing claims to personal property in Manila's Grand Hotel. Plaintiffs claimed ownership through valid pledge contracts and a bill of sale securing debts totaling P6,500, while defendant landlord claimed a lien for P2,250 unpaid rent. The Supreme Court affirmed the lower court's judgment favoring plaintiffs, ruling that Article 1922(7) of the Civil Code granting landlord's liens applies only when the debtor retains ownership. Since Bayer had validly pledged the furniture to secure debts and later sold it to plaintiff Estella L.P. Macke, with actual possession transferred to a third party, no landlord's lien could attach. The Court emphasized that pledgee rights under the Civil Code take priority over landlord's claims when property ownership has been transferred through valid security arrangements.