THE STANDARD OIL COMPANY OF NEW YORK

vs. JOAQUIN JARAMILLO

G.R. No. L-20329
March 16, 1923
FACTS:

De la Rosa was the lessee of a piece of land, on which a house she owns was built

She executed a chattel mortgage in favor of the Standard Oil Co.

Standard Oil Co. moved for its registration with the Register of Deeds, for the purpose of
having the same recorded in the book of record of chattel mortgages

Registrar (Jaramillo) refused the registration since after examination,

opinion that the properties were not subjects of a chattel mortgage

he

was

in

the

LAW/S:

ACT NO. 1508 as amended by ACT NO. 2496

Chattel Mortgage Law

SEC. 5: Register of Deeds has no authority to pass upon the capacity of the
parties to a chattel mortgage which is presented to him for record and the
character of the property sought to be encumbered by a chattel mortgage

ADMINISTRATIVE CODE (SEC. 198)

There is nothing in any of these provisions conferring upon the register of deeds any
authority whatever in respect to the "qualification," as the term is used in Spanish
law, of chattel mortgage
Duty of registrar is purely ministerial in character

ISSUE/S:

Whether or not the deed may be registered in the chattel mortgage registry.

RULING:

YES, THEY MAY BE REGISTERED

Registrars duty is ministerial in character he should therefore accept the legal fees
being tendered and place the document on record
No legal provision conferring any judicial or quasi-judicial power to determine the
nature of the document presented before him

NOTE:

Efficacy of the act of recording a chattel mortgage consists in the fact that it operates as
constructive notice of the existence of the contract, and the legal effects of the contract
must be discovered in the instrument itself in relation with the fact of notice