Casabuena vs. CA (286 SCRA 594)

Casabuena vs. CA (286 SCRA 594)

Facts:
Ciriaco Urdaneta (Ciriaco) was indebted to Benin, to secure which debt the spouses Urdaneta ceded their rights over the land through a deed of assignment. A deed of sale with mortgage was executed, with Urdaneta undertaking to pay the City. After having incurred additional, Ciriaco executed another deed of assignment involving the whole lot, with assignee Benin agreeing to shoulder all obligations including the payment of amortization to the City. The parties verbally agreed that Urdaneta could redeem the property upon payment of the loan; failure to pay would transfer physical possession of the lot to Benin, without actual transfer of title and ownership thereto. A Transfer Certificate of Title was issued in the name of Spouses Urdaneta or Ciriaco, married to Ofelia Ipil. Benin had transferred her right, title and interest of the land for a consideration to Casabuena, Benin's rental collector and lessee on the duplex erected on the land. However, their relationship soured, compelling the Benin to filed a complaint for ejectment against Casabuena, alleging that the Casabuena stopped paying rentals.

Issue:
Can a deed of assignment transfer ownership of the property to the assignee.

Held:
No, a deed of assignment does not transfer ownership of the property to the assignee. An assignment of credit is an agreement by virtue of which the owner of a credit, known as the assignor, by a legal cause, transfers his credit and its accessory rights to another, known as the assignee, who acquires the power to enforce it to the same extent as the assignor could have enforced it against the debtor. The assignment involves no transfer of ownership but merely effects the transfer rights which the assignor has at the time, to the assignee. The act of assignment could not have operated to efface liens or restrictions burdening the right assigned, because an assignee cannot acquire a greater right than that pertaining to the assignor. At most, an assignee can only acquire rights duplicating those which his assignor is entitled by law to exercise.

​ Here, Benin having been deemed subrogated to the rights and obligations of the spouses Urdaneta, she was bound by exactly the same conditions to which the spouses were bound. Not having acquired any right over the land in question, it follows that Benin conveyed nothing to Casabuena with respect to the property. Hence, notwithstanding the encumbrance of the Bulacan lot through a deed of assignment in favor of Benin, the spouses Urdaneta remain its owners, to the exclusion of Casabuena.