Case Digest (G.R. No. L-18536)
Facts:
Jose B. Aznar v. Rafael Yap-Diangco; Teodoro Santos, G.R. No. L-18536, March 31, 1965, the Supreme Court En Banc, Regala, J., writing for the Court.
The dispute arose over a Ford Fairlane 500 originally owned by intervenor Teodoro Santos, who advertised the car for sale in May 1959. On May 28, 1959 a man named L. De Dios, purporting to act for Vicente Marella, contacted Santos’s son, Irineo Santos, and arranged an inspection. On May 29, 1959, Irineo met Marella, who agreed to buy the car for P14,700 on the understanding that payment would follow registration in his name. A deed of sale was executed at the office of Atty. Jose Padolina and the Motor Vehicles Office in Quezon City registered the car in Marella’s name, but no payment was made and the car was not delivered to Marella.
Teodoro Santos gave the registration papers and a copy of the deed of sale to Irineo and instructed him not to surrender them until full payment was made. Afterwards Irineo and L. De Dios went to Marella’s address where Marella claimed he was short P2,000 and asked them to fetch a sister on Azcarraga Street; Marella requested the registration papers to show his lawyers, and Irineo handed them over. At Azcarraga, De Dios disappeared and the car and an unidentified companion vanished; Irineo discovered the car gone and reported the incident to his father and the police. That same afternoon Marella sold the car to Jose B. Aznar for P15,000. The trial court’s factual finding — accepted by the Supreme Court — was that Aznar acquired the car in good faith, for value, and without notice of any defect in Marella’s title.
While Aznar was registering the car in his name, agents of the Philippine Constabulary seized it pursuant to Santos’s complaint. Aznar sued Captain Rafael Yap-Diangco, head of the Constabulary unit, in replevin seeking delivery of the car; Teodoro Santos was allowed to intervene. The Co...(Pro-only)
Issues:
- Is Article 1506 of the Civil Code applicable so that a buyer in good faith (Aznar) acquires title from a vendee (Marella) whose title was only voidable or defective?
- Does Article 559 of the Civil Code entitle the original owner (Santos), who was unlawfully deprived of a movable, to recover it from a good-faith purchaser (Aznar) without...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)