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:
- Plaintiff/Appellee: Rosalio Bautista, who acquired certain properties through a sale and subsequently entered into a lease arrangement.
- Defendant/Appellant: Raymundo de la Cruz, who later acquired the camarin through a subsequent sale.
- Other Defendants:
- Francisco Sioson, the original vendor who executed two separate sales concerning the camarin.
- Francisco Santos Paulino, involved in possession of the house but ultimately absolved from the complaint.
- The case centers on the ownership of a camarin (warehouse) built of strong materials with an iron roof, and other related real properties in Malabon, Rizal.
Parties and Background
- First Sale (September 4, 1912)
- Rosalio Bautista purchased the camarin and a house from Francisco Sioson and his wife, Lorenza de la Cruz, for P400.
- The transaction was effected through a notarial instrument under a right of repurchase clause, which stipulated that the vendors could regain the property within two years by repurchasing it.
- On the same date, Bautista leased the properties back to the vendors under a constitutum possessorium agreement for a period of two years at an annual rent of P100.
- Subsequent Events
- On June 12, 1913, Lorenza de la Cruz died, impacting the vendor’s capacity in subsequent transactions.
- Second Sale (August 5, 1914)
- Francisco Sioson, despite being involved in the earlier sale, executed a second sale of the camarin to Raymundo de la Cruz.
- This sale was also under a repurchase agreement, stipulating that if the vendor did not redeem the camarin within six months by returning P422, the sale would become absolute.
- Notably, this second sale occurred when Sioson was in possession of the camarin as a tenant/lessee under the prior lease, not as the outright owner.
Transaction History and Contracts
- Rosalio Bautista’s Acquisition
- Upon the lapse of the two-year repurchase period without the vendors exercising their right, Bautista’s ownership was deemed consolidated.
- Bautista had taken symbolic delivery by way of the notarial instrument and the subsequent lease agreement.
- Raymundo de la Cruz’s Position
- Although Cruz acquired the camarin through a notarial document, his acquisition was later in time and occurred while Sioson occupied the camarin as a tenant.
- Cruz’s possession was affected by his good faith belief, due to lack of recorded entry in the registry of properties, yet this possession was deemed unlawful because the seller (Sioson) was not the rightful owner at the time of the second sale.
Possession and Consolidation of Ownership
- In the Court of First Instance of Rizal, the decision included:
- Holding that Rosalio Bautista was, by merger, the owner of the properties described in the complaint.
- Ordering the delivery of the camarin to Bautista.
- Ordering payment of the due rent and costs against the defendants.
- Appeal Process
- Raymundo de la Cruz filed an appeal through a bill of exceptions.
- The appeal raised questions regarding the validity of the second sale and the effect of possession under the constitutum possessorium agreement.
Proceedings and Court Findings
Issue:
- Whether the camarin’s ownership consolidated in favor of Rosalio Bautista due to the lapse of the repurchase period after the first sale.
- Whether Raymundo de la Cruz, who acquired the camarin through a second sale by Francisco Sioson, could claim lawful title despite being in possession later.
- Whether Francisco Sioson, holding the camarin as a tenant (under the constitutum possessorium agreement), possessed the legal capacity to execute a subsequent sale.
- The legal implications of a sale effected by an individual not in full ownership but as a lessee.
- Which purchaser first took actual and symbolic possession of the camarin.
- How the Civil Code’s provisions, particularly Article 1473 (on conflicting sales and possession), apply to determine the rightful owner.
- The absence of entry in the registry of property for both notarial instruments and its effect on notice to subsequent purchasers.
- Whether this non-registration influenced the presumption of bona fide possession by Cruz.
Ownership Determination
Validity of the Second Sale
Role of Possession and Its Legality
Implications of Non-registration
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)