Case Digest (G.R. No. 80298) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Edca Publishing & Distributing Corp. v. The Spouses Leonor and Gerardo Santos, G.R. No. 80298, decided on April 26, 1990, the petitioner EDCA sold 406 books on October 5, 1981 to a man identifying himself as Professor Jose Cruz, who paid by check. Two days later, Cruz sold 120 of those books to private respondents Leonor and Gerardo Santos, doing business as Santos Bookstore, after showing EDCA’s invoice and paying P1,700.00. Suspecting fraud, EDCA learned that “Cruz” was actually Tomas de la Pena, arrested him with police help on October 7, and—without a warrant—forced entry into the respondents’ store, threatened Leonor Santos, and seized the 120 books. The Santoses sued for their return. The Municipal Trial Court of Manila ruled for the Santoses; the Regional Trial Court and the Court of Appeals affirmed. EDCA petitioned the Supreme Court, contending it was unlawfully deprived of its property when the impostor’s check bounced, nullifying Cruz’s title and entitling EDCA to Case Digest (G.R. No. 80298) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract of Sale and Initial Delivery
- On October 5, 1981, a man identifying himself as “Professor Jose Cruz” telephoned EDCA Publishing & Distributing Corp. (EDCA) to order 406 books, payable on delivery.
- EDCA issued an invoice, delivered the 406 books, and accepted a personal check for ₱8,995.65.
- Subsequent Sale to Private Respondents
- On October 7, 1981, “Cruz” sold 120 of those books to Leonor Santos (doing business with her husband under Santos Bookstore) for ₱1,700, showing her the EDCA invoice to verify ownership.
- Private respondent Leonor Santos, a bookseller, paid in cash after confirming the books belonged to “Cruz.”
- Discovery of Deception and Seizure
- EDCA grew suspicious when Cruz placed a second order before the first check cleared. Inquiries at De La Salle College and Philippine Amanah Bank revealed no “Jose Cruz” and no bank account.
- The police set a trap, arrested the impostor (real name: Tomas de la Pena) on October 7, and—at EDCA’s behest—forced entry into Santos Bookstore without warrant, threatened prosecution of Leonor Santos, and seized the 120 books, thereafter returning them to EDCA.
- Judicial Proceedings
- The private respondents sued EDCA for recovery of the books after demand was refused; a writ of preliminary attachment was issued, and EDCA surrendered the books.
- The Municipal Trial Court, the Regional Trial Court, and the Court of Appeals all ruled in favor of the private respondents, recognizing their ownership under Article 559 of the Civil Code. EDCA then filed a petition for review with the Supreme Court.
Issues:
- Does the possession of movable property acquired in good faith confer title equivalent to ownership under Article 559 of the Civil Code?
- Can EDCA be deemed “unlawfully deprived” of the books due to the dishonor of the payment check, thereby entitling it to recover the books from the good‐faith purchasers?
- Was EDCA’s forcible recovery of the books, with police assistance and without warrant, legally permissible?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)