Saturday, December 15, 2012

Several claimants to a warehouse receipt



What is the duty of warehouseman when there are several claimants to a warehouse receipt?

The warehouseman may either:

a.   Investigate and determine within a reasonable time the validity of the claims, and deliver to the person whom he finds is entitled to the possession of the goods

Effect:  He is NOT excused from liability in case he makes a mistake

b.   He may bring a complaint in interpleader

Effect:  a)  he will be relieved from liability in delivering the goods to the person whom the court finds to have better right;

b)    he is liable for refusal to deliver to the rightful claimant when it is required to have an interpleader;

c.    He may not do (a) and (b)

Effect:  He will be liable after a lapse of a reasonable time, of conversion as of the date of the original demand for the goods.

NOTE: This does NOT apply to cases where the warehouseman himself makes a claim to the goods.

Co-mingling of deposited goods

GR:  A warehouseman may not co-mingle goods belonging to different depositors.

Exception In case of fungible goods of the same kind and grade provided:

a.    he is authorized by agreement

b.    he is authorized by custom
           Effects: 
a.    each depositor shall own the entire mass in common and entitled to his portion

b.    warehouseman is severally liable to each depositor for the care and redelivery of their portion as if the goods had been kept separate

Attachment or levy or negotiable receipts 
  • A warehouseman has the obligation to hold the goods for the owner or for the person to whom the negotiable receipt has been duly negotiated.

 Therefore, the goods cannot be attached or levied upon under an execution UNLESS:

a.       the document be first surrendered; or
b.       the negotiation is enjoined, or
c.       the document is impounded by the court

  • The warehouseman cannot be compelled to deliver the goods until:

a.       the receipt is surrendered to him;
b.       it is impounded by the court

NOTE:  This provision does NOT apply if the person depositing is NOT the owner of the goods or one who has not the right to convey title to the goods binding upon the owner.

What is the remedy of creditor whose debtor owns a negotiable receipt?
 Attachment of the negotiable receipt (NOT the goods)

NOTE:  the goods themselves cannot readily be attached or levied upon by ordinary legal process

What is the extent of warehouseman’s lien?

a.   lawful charges for
1.   storage, and
2.   preservation of the goods

b.   lawful claims for
1.   money advanced        5. labor
2.   interest                        6. weighing
3.   insurance                    7. cooperating
4.   transportation

c.    other charges and expenses in relation to such goods

d.   reasonable charges and expenses for notice and advertisements of sale

e.   sale of the goods where defaults has been made in satisfying the lien

What is the extent of the lien when a negotiable receipt has been issued?

a.   charges for storage and preservation of the goods

b.   other charges expressly enumerated (from b, c, d and e above) although the amount is NOT stated

NOTE:  For claims not specified, the warehouseman shares pro rata with the other creditors of the depositor the balance of the proceeds of the sale for the satisfaction of the claims.

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