Facts:

The case of Mariano Belleza vs. Aniceto Zandaga and the Provincial Sheriff of La Union revolves around a dispute over ownership and possession of a piece of land. The plaintiff, Mariano Belleza, purchased the land at an execution sale, receiving a definitive deed of sale on July 25, 1947. Shortly thereafter, on July 31, 1947, Deputy Sheriff Emilio de Guzman placed Belleza in possession of the property, which was identified by the barrio lieutenant, Aniceto Zandaga. However, it was later discovered that the land Belleza was given possession of was not the same as that described in the deed. Instead, Zandaga was occupying the actual land purchased by Belleza. Upon realizing this discrepancy, Belleza demanded possession of the correct property, but Zandaga refused, claiming to be the "successor in interest" of the judgment debtor. Belleza's complaint sought a court order for Zandaga to prove his title to the land, asserting that if Zandaga's title was inferior,...

Facts:

1. Purchase of Land at Execution Sale:

   • Mariano Belleza (plaintiff) purchased a piece of land at an execution sale.
   • A definitive deed of sale was issued to him on July 25, 1947.

2. Possession of Incorrect Land:

   • On July 31, 1947, the deputy sheriff, Emilio Cle Guzman, placed Belleza in possession of a piece of land pointed out by Aniceto Zandaga (defendant), the barrio lieutenant.
   • The land given to Belleza was later discovered to be different from the one described in the deed.

3. Discovery of True Ownership:

   • Belleza found that the land described in the deed was occupied by Zandaga, who claimed to be the "successor in interest" of the judgment debtor.
   • Belleza demanded possession of the correct land, but Zandaga refused.

4. Allegations in the Complaint:

   • Belleza alleged that Zandaga willfully and maliciously concealed the identity of the property, depriving him of possession and enjoyment of its fruits.
   • Belleza sought a declaration of ownership, possession, damages, attorney’s fees, and costs. He also asked for the provincial sheriff to be subsidiarily liable if Zandaga could not pay.

5. Motion to Dismiss:

   • Both defendants (Zandaga and the provincial sheriff) moved to dismiss the complaint, arguing it did not state a cause of action.
   • The trial court granted the motion, prompting Belleza to appeal directly to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Legal Title and Ownership:

   • Upon receipt of the definitive deed of sale, legal title over the property is perfected, and ownership is consolidated in the purchaser.
   • The purchaser, as the absolute owner, is entitled to possession and the fruits of the property.

2. Cause of Action Against Zandaga:

   • Zandaga’s claim as a "successor in interest" of the judgment debtor does not automatically negate Belleza’s right to possession.
   • The court cannot prematurely conclude that Zandaga has a better right without proper adjudication.

3. Subsidiary Liability of the Sheriff:

   • The complaint lacked sufficient allegations to establish the provincial sheriff’s subsidiary liability.

4. Rule 39, Section 32:

   • The rule provides an alternative remedy but does not preclude the purchaser from seeking possession directly.