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  • University of The Philippines College of Law: Siari Valley v. Lucasan

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    Juno Geronimo
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    The Supreme Court affirmed the lower court's ruling granting Siari Valley the right to recover all cattle, including offspring, driven to Lucasan's ranch. While some cattle initially strayed onto Lucasan's land, he later deliberately drove cattle from Siari Valley's ranch to his own. This constituted bad faith under Article 473 of the Civil Code, allowing Siari Valley to recover all cattle commingled on Lucasan's ranch, including offspring, due to Lucasan's responsibility for the bad faith commingling.

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    Property digest

    Original Title

    20 Siari Valley v. Lucasan

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    The Supreme Court affirmed the lower court's ruling granting Siari Valley the right to recover all cattle, including offspring, driven to Lucasan's ranch. While some cattle initially strayed onto Lucasan's land, he later deliberately drove cattle from Siari Valley's ranch to his own. This constituted bad faith under Article 473 of the Civil Code, allowing Siari Valley to recover all cattle commingled on Lucasan's ranch, including offspring, due to Lucasan's responsibility for the bad faith commingling.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    129 views2 pages

    University of The Philippines College of Law: Siari Valley v. Lucasan

    Uploaded by

    Juno Geronimo
    The Supreme Court affirmed the lower court's ruling granting Siari Valley the right to recover all cattle, including offspring, driven to Lucasan's ranch. While some cattle initially strayed onto Lucasan's land, he later deliberately drove cattle from Siari Valley's ranch to his own. This constituted bad faith under Article 473 of the Civil Code, allowing Siari Valley to recover all cattle commingled on Lucasan's ranch, including offspring, due to Lucasan's responsibility for the bad faith commingling.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    of 2

    University of the Philippines College of Law

    Block F2021

    Topic Right of Accession with respect to Movable Property – Rules in Mixture (Art. 472-
    73)
    Case No. G.R. No. L-7046 / Aug. 31, 1955
    Case Name Siari Valley v. Lucasan
    Ponente J. Bengzon
    Case assigned to Cole and Juno

    QUICK SUMMARY

    Judgment granting ALL the cattle to Siari Valley in virtue of bad faith of defendant Lucasan by
    deliberately and willfully “driving and rounding up the cattles from Siari Valley ranch to his adjacent
    ranch” making Art. 473 of NCC on comingling rules applicable.

    RELEVANT FACTS

     This is an appeal from the decision of CFI of Zamboanga on an action to recover about 700 (upon
    computation) heads of cattle that were driven, or wandered, from the pasture lands of petitioner Siari
    Valley into the adjoining ranch of defendant Filemon Lucasan, Sindangan, Zamboanga;

     Plaintiff Siari Valley asked for the return of its animals with their offspring, or for payment of those
    disposed of by defendant, plus damages. On the other hand, the defendant Lucasan alleged that thru
    force and intimidation, Siary Valley took 105 heads of cattle from him, of which he also demand
    compensation;

     It was established that initially, some of the cattle simply strayed to the ranch of Lucasan, and Lucasan
    duly informed Siari Valley of this. But on the succeeding instances, there was willful and deliberate
    intent on the side of Lucasan (with his own sons, and men involved) to round up and drove the cattle
    from Siari Valley to the Lucasan’s ranch;

     The cattle in Lucasan’s ranch reproduced “mestizos” or “hybrid” cattle, upon inspection. It was
    established that defendant Lucasan’s herd were purely native at the onset;

     Lower court ruled for Siari Valley, and ordered that ALL the cattle found in the ranch of Lucasan be
    delivered to Siari Valley

    ISSUE

     W/N Siari Valley has the right recover ALL the cattle, including their offspring, driven to the ranch of
    Lucasan
    University of the Philippines College of Law
    Block F2021

    RATIO DECIDENDI

    Issue Ratio
    W/N Siari Valley has the Yes.
    right recover ALL the
    cattle, including their Although there was no sufficient evidence that all the missing animals were
    offspring, driven to the taken by Lucasan or his men, it is not impossible that he have taken the
    ranch of Lucasan others as well on virtue of those instance that he deliberately did drive the
    cattles to his ranch. The Court applied by analogy, the principle that one who
    stole a part of the stolen money must have taken also the larger sum lost by
    the offended party.

    And although generally, offspring or the increase of domestic animals belongs


    to the owner of the dam (mother) by accretion, the bad faith on side of
    Lucasan makes the Art. 473 of NCC applicable on this case: "if the
    commingling of two things is made in bad faith, the one responsible for it
    will lose his share x x x"

    RULING

    Therefore it is hereby affirmed, with costs against appellant. So ordered.

    NO SEPARATE OPINION

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