Title
Aznar vs. Yapdiangco
Case
G.R. No. L-18536
Decision Date
Mar 31, 1965
Teodoro Santos, unlawfully deprived of his car by Vicente Marella, successfully reclaimed it from Jose Aznar, who acquired it in good faith, as ownership was never transferred due to lack of delivery.
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Case Digest (G.R. No. L-18536)

Facts:

1. Advertisement and Initial Contact:

  • In May 1959, Teodoro Santos advertised the sale of his Ford Fairlane 500 in two metropolitan newspapers.
  • On May 28, 1959, L. De Dios, claiming to be a nephew of Vicente Marella, visited Santos' residence to inquire about the car. Santos was not home, so his son, Irineo Santos, spoke with De Dios.
  • De Dios stated that he was acting on behalf of Vicente Marella, who was interested in purchasing the car.

2. Agreement and Execution of Deed of Sale:

  • On May 29, 1959, Irineo Santos met with Vicente Marella at 1642 Crisostomo Street, Sampaloc, Manila.
  • Marella agreed to buy the car for P14,700, with the condition that payment would be made after the car was registered in his name.
  • A deed of sale was executed in Marella's favor at the office of Atty. Jose Padolina.
  • The car was subsequently registered in Marella's name at the Motor Vehicles' Office in Quezon City.

3. Non-Payment and Theft of the Car:

  • After registration, Teodoro Santos instructed his son, Irineo, not to release the registration papers and deed of sale until full payment was made.
  • Irineo Santos and L. De Dios went to Marella's address to demand payment. Marella claimed he was short by P2,000 and asked to retrieve the amount from his sister in Azcarraga Street.
  • Marella requested the registration papers and deed of sale, which Irineo handed over, trusting Marella's good faith.
  • At Azcarraga Street, L. De Dios disappeared, and the car was stolen.

4. Sale to Jose B. Aznar:

  • On the same day, May 29, 1959, Vicente Marella sold the car to Jose B. Aznar for P15,000.
  • Aznar acquired the car in good faith, without notice of any defect in Marella's title.

5. Seizure of the Car:

  • The car was seized by the Philippine Constabulary upon Teodoro Santos' report that it had been unlawfully taken from him.
  • Aznar filed a complaint for replevin against Captain Rafael Yapdiangco, seeking the return of the car.

6. Intervention by Teodoro Santos:

  • Teodoro Santos intervened in the case, claiming ownership of the car.
  • The lower court ruled in favor of Santos, awarding him possession of the car.

Issue:

The primary issue in this case is:

  • Between Teodoro Santos and Jose B. Aznar, who has a better right to the possession of the disputed automobile?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court dismissed Jose B. Aznar's appeal and affirmed the lower court's decision, awarding possession of the car to Teodoro Santos. The Court held that Santos, as the rightful owner, could recover the car from Aznar, even though Aznar had acquired it in good faith, because Santos had been unlawfully deprived of the vehicle.


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