Huwebes, Disyembre 6, 2012

Standard Oil Co. v. Jaranillo 
44 Phil. 631

FACTS: De la Rosa, who was renting a parcel of land in Manila, constructed a building of strong materials thereon, which she conveyed to plaintiff Standard Oil Co. by way of chattel mortgage. When the mortgagee was presenting the deed to the Register of Deeds of Manila for registration in the Chattel Mortgage Registry, the Registrar refused to allow the registration on the ground that the building was a real property, not personal property, and therefore could not be the subject of a valid chattel mortgage.


ISSUE: May the deed be registered in the chattel mortgage registry?

HELD: Yes, because the Registrar's duty is MINISTERIAL in character.There is no legal provision conferring upon him any judicial or quasi-judicial power to determine the nature of the document presented before him. He should therefore accept the legal fees being tendered, and place the document on record.

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