Case Summary (G.R. No. 192514)
Chronology of the Initial Sale Transaction
In May 1959, Teodoro Santos advertised his Ford Fairlane. On May 29, his son Irineo, acting on instructions, met Vicente Marella at Crisostomo Street. Marella agreed to purchase for ₱14,700, payment to follow registration. A deed of sale was executed before Atty. José Padolina, and registration in Marella’s name was effected. Title and ownership, however, remained with Santos until full payment and actual delivery.
Scheme of Deprivation and Theft
After registration, Santos’s son and L. De Dios demanded payment from Marella, who claimed a ₱2,000 shortfall and proposed to fetch the balance from his “sister” on Azcárraga Street. Marella obtained the registration papers and the deed of sale from Irineo under the pretext of legal consultation, then lured Irineo and De Dios to the sister’s house. There, Marella’s accomplice and the vehicle disappeared, and Marella closed his Sampaloc residence.
Subsequent Sale to Appellant and Seizure
Later on May 29, Marella sold the same car to Jose B. Aznar for ₱15,000. While Aznar was attending to registration in his name, Santos reported the theft to the Philippine Constabulary. Captain Yap-Diangco’s unit seized the car, prompting Aznar to file a replevin action against Yap-Diangco for its restitution.
Trial Court Proceedings and Lower Court Ruling
The Court of First Instance of Quezon City allowed Santos to intervene. It found that: (1) Santos was the original owner unlawfully deprived of the car; (2) Aznar was a good-faith purchaser for value but acquired from a thief; and (3) under Article 559 of the Civil Code, an owner may reclaim a movable unlawfully taken, even from a bona fide purchaser, without indemnity except in cases of public sale. The court awarded possession to Santos.
Legal Issue on Appeal
Whether Aznar’s good faith purchase from Marella vested in him a better right to possession under Article 1506 (voidable title) or whether Santos’s right to reclaim under Article 559 (unlawful deprivation) prevailed.
Inapplicability of Article 1506
Article 1506 protects buyers from sellers holding a voidable title. Marella never acquired ownership because, under Article 712, title to movables transfers only by tradition (delivery), not by contract alone. Here, no valid tradition occurred; Marella’s “possession” was a theft, not the delivery required
...continue readingCase Syllabus (G.R. No. 192514)
Facts
- In May 1959, Teodoro Santos advertised his Ford Fairlane 500 for sale in two metropolitan newspapers.
- On May 28, 1959, L. De Dios, claiming to represent Vicente Marella, inquired about the car; he spoke with Santos’s son, Irineo.
- Teodoro Santos instructed Irineo to meet Vicente Marella at 1642 Crisostomo Street, Sampaloc, Manila, the next morning.
- May 29, 1959: Marella agreed to purchase the car for ₱14,700, with payment deferred until registration in his name.
- Santos, De Dios, Marella and Irineo Santos executed a deed of sale before Atty. Jose Padolina and then registered the car at the Quezon City Motor Vehicles Office.
- Santos retained possession of the car and delivered the registration papers and a copy of the deed of sale to Irineo, instructing him not to release them until full payment.
- At 1642 Crisostomo, Marella claimed he was ₱2,000 short, asked to fetch it from his sister on Azcárraga Street, and requested the papers to show his lawyers.
- Trusting Marella, Irineo handed over the papers and accompanied De Dios and an unidentified companion to the sister’s address.
- At the Azcárraga location, De Dios entered a house and never returned; the car, papers, and the unidentified companion disappeared.
- Irineo’s inquiries at the house yielded no information; Marella’s residence at Crisostomo was closed and Marella gone.
- That afternoon, Santos reported the theft to the police; Marella sold the car to Jose B. Aznar for ₱15,000.
- Philippine Constabula