STANDARD OIL CO. vs.

JARAMILLO

Facts:

On November 27, 1922, Gervasia de la Rosa, Vda. de Vera, was the lessee of a parcel of land
situated in the City of Manila and owner of the house of strong materials built thereon, upon which
date she executed a document in the form of a chattel mortgage to convey to the Standard Oil. Co. by
way of mortgage both the leasehold interest in said lot and the building to which it stands

After said document had been duly acknowledged and delivered, it was then presented to Joaquin
Jaramillo, Register of Deeds of the City of Manila, for the purpose of having the same recorded. Upon
examination of the instrument, the Jaramillo was of the opinion that it was not chattel mortgage, for
the reason that the interest therein mortgaged did not appear to be personal property, within the
meaning of the Chattel Mortgage Law, and registration was refused on this ground only.

Issue:

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

Held:

Yes it may be registered. The duties of a register of deeds in respect to the registration of chattel
mortgages are purely of a ministerial character, and he is clothed with no judicial or quasi-judicial
power to determine the nature of the property, whether real or personal, which is the subject of the
mortgage. Generally speaking, he should accept the qualification of the property adapted by the
person who presents the instrument for registration and should place the instrument on record, upon
payment of the proper fee, leaving the effects of registration to be determined by the court if such
question should arise for legal determination.

The efficacy of the act of recording a chattel mortgage consists in the fact that registration operates as
constructive notice of the existence of the contract, and the legal effects of the instrument must be
discovered in the document itself, in relation with the fact of notice. Registration adds nothing to the
instrument, considered as a source of title, and affects nobody's rights except as a species of
constructive notice.