Case Summary (G.R. No. 13125)
Background of the Case
- The case concerns an appeal by Raymundo de la Cruz against a judgment from the Court of First Instance of Rizal, which ruled in favor of plaintiff Rosalio Bautista regarding ownership of certain properties.
- The properties in question include a camarin (warehouse) and a house, originally sold to Bautista by Francisco Sioson and Lorenza de la Cruz under a contract that allowed for repurchase within two years.
Findings of the Court
- The Court determined the following key points:
- Bautista became the owner of the properties by merger due to the lapse of the two-year repurchase period without action from the vendors.
- Raymundo de la Cruz was ordered to deliver the camarin to Bautista.
- Francisco Sioson was ordered to pay Bautista P200 for unpaid rent.
- Francisco Santos Paulino was absolved from the case due to lack of evidence against him.
- Costs were split between the defendants.
Ownership and Possession
- The case primarily revolves around the question of ownership of the camarin:
- Rosalio Bautista's Claim: Bautista claimed ownership based on the sale and the subsequent lapse of the repurchase period, asserting that he held the rights as the first purchaser.
- Raymundo de la Cruz's Claim: De la Cruz argued that he purchased the camarin from Sioson after the initial sale to Bautista, believing himself to be the rightful owner.
Legal Principles Applied
- Civil Code Article 1473: This article states that if the same property is sold to different vendees, the rightful owner is the one who first took possession of it in good faith.
- Possession vs. Ownership: The Court clarified that actual possession does not equate to ownership if the possessor acquired the property from someone lacking the right to sell it.
Key Legal Definitions
- Camarin: A warehouse or storage structure.
- Constitutum Possessorium: A legal concept where a seller continues to possess the property as a tenant after sale, implying that previous ownership is not transferred until specific conditions are met.
Important Requirements and Procedures
- The sale must be documented by a notarial instrument, which serves as symbolic delivery of the property.
- The original vendors had to repurchase the properties within two years; failure to do so resulted in consolidation of ownership with the buyer.
Relevant Timeframes
- Two-Year Repurchase Period: The vendors had two years from September 4, 1912, to repurchase the camarin.
- Six-Month Redemption Period: Sioson had six months from August 1, 1914, to redeem the camarin sold to de la Cruz.
Consequences of the Judgment
- De la Cruz's ownership claim was dismissed as he acquired the property from Sioson, who was merely a tenant and could not legally transfer ownership.
- Bautista retained ownership of the camarin, and de la Cruz was ordered to surrender the propert
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 agreement, which allowed Sioso