Compañia General de Tabacos de Filipinas v. Alfredo Jeanjaquet

Summary

The Supreme Court En Banc affirmed a debt collection judgment against Alfredo Jeanjaquet in favor of Compañia General de Tabacos de Filipinas for P55,829.15 plus interest and costs. While Jeanjaquet had executed a mortgage in 1904 to secure the debt, the mortgage was never registered in the property registry as required by Civil Code article 1875, rendering it invalid as security. However, the Court held that the failure to properly constitute the mortgage did not affect the validity of the underlying debt obligation, which was clearly established through the mortgage document itself and company account records. The Court distinguished between the invalid mortgage security and the valid principal obligation, setting aside the foreclosure order while affirming the debt collection judgment. This case establishes the principle that improper mortgage constitution does not invalidate the underlying debt, and creditors may still pursue ordinary collection remedies even when specific security interests fail due to procedural defects.