Case Digest (G.R. No. L-18536) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose B. Aznar vs. Rafael Yap-Diangco; Teodoro Santos (Intervenor), decided March 31, 1965 under the 1935 Constitution, Teodoro Santos advertised on May 28, 1959 the sale of his Ford Fairlane 500. His son Irineo spoke with L. De Dios, purported agent of Vicente Marella. On May 29, Irineo and De Dios met Marella at his home in Sampaloc, Manila; Marella agreed to buy the car for ₱14,700 on the condition that registration be effected first. Santos and De Dios executed a deed of sale before Atty. Padolina and registered the vehicle in Marella’s name, though Marella did not pay. Santos delivered the registration papers and sale instrument to Irineo, instructing him to await full payment. Irineo and De Dios then went with an unidentified companion to an alleged sister’s house on Azcárraga Street, where De Dios entered a room and vanished; the companion drove off with the car. Irineo’s inquiry revealed no Marella kin; Marella likewise disappeared from his Crisóstomo Street address. S Case Digest (G.R. No. L-18536) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial advertisement and contact
- In May 1959, Teodoro Santos advertised his Ford Fairlane 500 for sale in two metropolitan newspapers.
- On May 28, 1959, L. De Dios—claiming to represent his uncle Vicente Marella—called at Santos’s residence and spoke with Irineo Santos in his father’s absence.
- Negotiation and execution of sale to Marella
- On the morning of May 29, 1959, Irineo met Marella at 1642 Crisostomo Street, Sampaloc, Manila, where Marella agreed to buy the car for ₱14,700, payment to follow registration.
- Teodoro Santos, Irineo, and De Dios then executed a deed of sale before Atty. José Padolina and registered the vehicle in Marella’s name at the Motor Vehicles Office, without Marella having paid any part of the purchase price.
- Retention of documents and fraudulent misappropriation
- Santos gave Irineo the registration papers and a copy of the deed, instructing him not to release them until full payment.
- At Marella’s direction, Irineo and De Dios went to an alleged sister’s home in Azcárraga Street; there, De Dios and an unidentified companion stole the car and disappeared, leaving Irineo stranded.
- Subsequent sale and judicial proceedings
- Later on May 29, 1959, Marella sold the car to Jose B. Aznar for ₱15,000; Aznar paid value in good faith without notice of defect.
- Upon Santos’s report, Philippine Constabulary agents under Capt. Rafael Yap-Diangco seized the vehicle during its registration in Aznar’s name.
- Aznar filed a replevin complaint against Capt. Yap-Diangco; Santos intervened and claimed rightful possession.
- The Court of First Instance awarded the car to Santos under Article 559 of the Civil Code; Aznar appealed.
Issues:
- Between original owner Teodoro Santos and good-faith purchaser Jose B. Aznar, who holds the superior right to possession of the car?
- Which Civil Code provision governs: Article 559 (recovery by an owner unlawfully deprived) or Article 1506 (good-faith purchaser from a seller with voidable title)?
- Whether Vicente Marella ever acquired title in the absence of delivery (tradition) under Article 712.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)