Case Summary (G.R. No. 80298)
Factual Background and Fraudulent Transaction
On October 5, 1981, the impostor (“Cruz”) ordered 406 books from EDCA, issued a personal check for ₱8,995.65, and received delivery. Two days later, he sold 120 volumes to Leonor Santos for ₱1,700, presenting EDCA’s invoice as proof of ownership.
Discovery of Impostor and Dishonored Check
EDCA grew suspicious of a second order before check clearance. Inquiries at De La Salle College and Philippine Amanah Bank revealed no “Jose Cruz” or valid account. A police sting led to the arrest of Tomas de la Pena on October 7, 1981. Investigation revealed his sale of the books to the Santoses.
Seizure Without Warrant and Self-Help Recovery
That night, EDCA, aided by Precinct 5 police, forcibly entered Santos Bookstore without a warrant, threatened prosecution for receiving stolen property, and seized the 120 books, loading them onto an EDCA van.
Proceedings Below and Petition to Supreme Court
The Santoses filed an action for recovery of the books. A writ of preliminary attachment issued; EDCA initially resisted but later surrendered the books under court order. Municipal, Regional, and Appeals courts ruled in favor of the Santoses, prompting EDCA’s petition for certiorari.
Court’s Condemnation of Self-Help and Police Misconduct
The Supreme Court criticizes EDCA’s resort to force and police compulsion, emphasizing that lawful processes—not brute force—must determine ownership disputes.
Good Faith Possession as Equivalent to Title
Under Article 559, possession of movable property acquired in good faith is equivalent to title, “dispensing with further proof.” The Santoses verified ownership via EDCA’s invoice and purchased in the ordinary course of their bookstore business, manifesting no bad faith.
Petitioner’s Argument on Nullity of Sale
EDCA contends its sale to the impostor is void for failure of consideration when the check bounced, thereby rendering Cruz’s title invalid and justifying recovery from subsequent possessors under Article 559.
Civil Code on Perfection and Transfer of Ownership
Articles 1475, 1477, and 1478 establish that a consensual sale is perfected upon meeting of minds on the object and price, and ownership passes upon delivery unless the parties stipulate retention of title until full payment. No such stipulation existed here.
Jurisprudential Support: Asiatic Commercial and Tagatac Cases
- Asiatic Commercial Corp. v. Ang: Goods voluntarily parted with under a valid sale, even if unpaid, cannot be recovered from third purchasers in go
Case Syllabus (G.R. No. 80298)
Facts
- On October 5, 1981, a man identifying himself as Professor Jose Cruz phoned EDCA Publishing & Distributing Corp. and ordered 406 books, payable on delivery.
- EDCA prepared an invoice and delivered the books; Cruz issued a personal check for ₱8,995.65.
- Two days later, Cruz sold 120 of those books to Leonor Santos for ₱1,700 after showing her EDCA’s invoice to prove his ownership.
- EDCA became suspicious when Cruz placed a second order before his first check cleared; inquiries at De la Salle College revealed no such dean, and the check bounced for lack of funds.
- EDCA enlisted police assistance, set a trap, and arrested Cruz (real name: Tomas de la Pena) on October 7, 1981; investigation disclosed his sale of the 120 books to the Santos couple.
- That same night, with police aid but without a warrant, EDCA agents forcibly entered the Santos bookstore, threatened Leonor Santos with prosecution for buying stolen goods, seized the 120 books, and turned them over to the petitioner.
- The private respondents protested, demanded return of the books, and—upon EDCA’s refusal—filed a recovery suit and obtained a writ of preliminary attachment. EDCA eventually surrendered the books.
Procedural History
- The Municipal Trial Court (Judge Jose B. Herrera) recognized the Santos spouses’ ownership of the 120 books.
- The Regional Trial Court (Judge Ernesto S. Tengco) affirmed the MTC’s decision.
- The Court of Appeals (Justices Buena, Castro-Bartolome, and Cacdac, Jr.) sustained both lower-court rulings.
- EDCA petitioned the Supreme Court to reverse the appellate decision.