Case Summary (G.R. No. 13125)

Legal Principles on Ownership of Real Property

• The lawful ownership of real property sold multiple times to different purchasers is determined by the first purchaser who took possession, as per Article 1473 of the Civil Code.
• In cases where the vendor becomes a lessee of the property sold, the purchaser is deemed to be in possession through the vendor's lease, establishing lawful ownership.
• A second purchaser who acquires property from a lessee cannot claim ownership, as the lessee lacks the authority to sell the property.

Case Background and Procedural History

• The appeal arises from a judgment by the Court of First Instance of Rizal, which ruled in favor of Rosalio Bautista, declaring him the owner of certain properties and ordering the defendants to deliver them.
• The complaint was filed by Bautista, asserting ownership based on a sale agreement with Francisco Sioson and Lorenza de la Cruz, which included a right of repurchase.
• The defendants, including Raymundo de la Cruz, contested the ownership, claiming exclusive rights to the camarin based on a subsequent sale.

Contracts and Transactions Involved

• On September 4, 1912, Sioson and de la Cruz sold the camarin to Bautista with a right of repurchase within two years.
• Bautista subsequently leased the camarin back to Sioson and de la Cruz, establishing a constitutum possessorium agreement.
• After the death of Lorenza de la Cruz, Sioson sold the camarin to Raymundo de la Cruz on August 5, 1914, under a similar right of repurchase.

Determining Lawful Ownership

• The core issue is whether Bautista or Raymundo de la Cruz holds lawful ownership of the camarin.
• Bautista's sale was not registered, and the right of repurchase had not expired at the time of Sioson's second sale to Cruz.
• The law presumes that Cruz acted in good faith, believing Sioson was the rightful owner due to the lack of registration of the first sale.

Analysis of Possession and Rights

• Despite Cruz's good faith, his possession does not grant him superior rights over Bautista, who was the first purchaser.
• The execution of the lease agreement indicates that Bautista retained ownership and that Sioson's possession was as a tenant, not as an owner.
• The...continue reading

Case Syllabus (G.R. No. 13125)

Background of the Case

• This case concerns an appeal made by Raymundo de la Cruz from a judgment rendered on December 29, 1916, by the Court of First Instance of Rizal.
• The judgment adjudicated ownership claims over certain properties, including a camarin (warehouse) and a house, which were sold under a contract with a right of repurchase.

Parties Involved

• Rosalio Bautista: Plaintiff and Appellee, who claims ownership of the properties.
• Francisco Sioson and Lorenza de la Cruz: Original vendors who sold the properties to Bautista.
• Raymundo de la Cruz: Defendant and Appellant, who claims ownership of the camarin based on a subsequent purchase from Sioson.
• Francisco Santos Paulino: Defendant, absolved from the complaint as there was insufficient evidence of possession.

Facts of the Case

• On September 4, 1912, Bautista purchased the camarin and a house from the spouses Sioson under a notarial sale that included a provision for repurchase within two years.
• Bautista subsequently leased the properties back to the Siosons for a period of two years at an annual rent of P100.
• Lorenza de la Cruz died on June 12, 1913.
• On August 5, 1914, Francisco Sioson sold the camarin to Raymundo de la Cruz under a similar right of repurchase ...continue reading