Title
Bautista vs. De la Cruz
Case
G.R. No. 13125
Decision Date
Feb 11, 1919
Dispute over camarin ownership between first purchaser Bautista and second purchaser de la Cruz; Supreme Court upheld Bautista's ownership, invalidating second sale.
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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:
    1. Bautista became the owner of the properties by merger due to the lapse of the two-year repurchase period without action from the vendors.
    2. Raymundo de la Cruz was ordered to deliver the camarin to Bautista.
    3. Francisco Sioson was ordered to pay Bautista P200 for unpaid rent.
    4. Francisco Santos Paulino was absolved from the case due to lack of evidence against him.
    5. 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

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