Case Digest (G.R. No. 13125)
Facts:
The case involves Rosalio Bautista as the plaintiff and appellee, and Raymundo de la Cruz and Francisco Sioson as the defendants. The events leading to the case began on September 4, 1912, when Bautista entered into a contract of sale with Sioson and his wife, Lorenza de la Cruz, for a camarin (warehouse) and a house located in Malabon, Rizal. The sale was executed under the condition that the vendors could repurchase the properties within two years. Following the sale, Bautista leased the properties back to Sioson and de la Cruz for an annual rent of P100. However, the vendors failed to repurchase the properties within the stipulated time, and the lease payments were not made.
On June 30, 1916, Bautista filed a complaint in the Court of First Instance of Rizal, asserting that he had become the owner of the properties due to the lapse of the repurchase period. He sought the return of the camarin and payment for unpaid rent. Sioson and de la Cruz did not respond to the comp...
Case Digest (G.R. No. 13125)
Facts:
Parties Involved:
- Plaintiff and Appellee: Rosalio Bautista.
- Defendants: Francisco Sioson, Lorenza de la Cruz (deceased), Francisco Santos Paulino, and Raymundo de la Cruz (Appellant).
Property in Dispute:
- A camarin (warehouse) made of strong materials with an iron roof, located in Malabon, Rizal.
- A house of mixed materials with a nipa roof, also located in Malabon, Rizal.
Initial Sale and Lease:
- On September 4, 1912, Francisco Sioson and Lorenza de la Cruz sold the camarin and house to Rosalio Bautista for P400, with a right of repurchase within two years.
- On the same day, Bautista leased the properties back to Sioson and Lorenza de la Cruz for P100 annually for two years.
Death of Lorenza de la Cruz:
- Lorenza de la Cruz died on June 12, 1913.
Second Sale:
- On August 5, 1914, Francisco Sioson sold the camarin to Raymundo de la Cruz for P422, with a right of repurchase within six months.
Failure to Repurchase:
- Neither Sioson nor his successors repurchased the properties within the stipulated periods.
Legal Action:
- On June 30, 1916, Bautista filed a complaint seeking ownership consolidation and delivery of the properties, as well as payment of unpaid rent.
Court Proceedings:
- Francisco Sioson and Francisco Santos Paulino were declared in default.
- Raymundo de la Cruz admitted some allegations but claimed exclusive ownership of the camarin.
Trial Court Decision:
- The court ruled in favor of Bautista, ordering:
- Delivery of the camarin to Bautista.
- Payment of P200 in rent by Sioson.
- Absolution of Francisco Santos Paulino.
- Payment of half the costs by Sioson and Raymundo de la Cruz.
- The court ruled in favor of Bautista, ordering:
Appeal:
- Raymundo de la Cruz appealed the decision.
Issue:
- (Unlock)
Ruling:
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Ratio:
First Purchaser’s Rights:
- The first purchaser, Rosalio Bautista, acquired ownership of the camarin through symbolic delivery (constitutum possessorium) when the sale was executed. The lease agreement further confirmed Bautista’s ownership.
Symbolic Delivery:
- Under Article 1462 of the Civil Code, the execution of a public instrument of sale constitutes symbolic delivery, transferring ownership to the purchaser.
Good Faith of Second Purchaser:
- While Raymundo de la Cruz may have acted in good faith, his possession was unlawful because it was derived from a lessee (Sioson) who had no ownership rights to convey.
Precarious Possession:
- Sioson’s possession of the camarin was precarious and as a lessee, he could not transfer ownership to Raymundo de la Cruz.
Article 1473 of the Civil Code:
- The Court applied Article 1473, which states that in cases of double sale, ownership belongs to the first purchaser who took possession in good faith. Since Bautista was the first to take possession, he had superior rights over the camarin.
Invalidity of Second Sale:
- The second sale was invalid because Sioson, as a lessee, had no legal capacity to sell the camarin to Raymundo de la Cruz.
Conclusion:
The Supreme Court upheld the trial court’s decision, affirming Rosalio Bautista’s ownership of the camarin and ordering Raymundo de la Cruz to deliver the property to Bautista. The Court emphasized the importance of symbolic delivery and the rights of the first purchaser under Article 1473 of the Civil Code. The second sale was deemed invalid due to the seller’s lack of ownership rights at the time of the transaction.