Title
Ledesma vs. Court of Appeals
Case
G.R. No. 86051
Decision Date
Sep 1, 1992
A fraudulent vehicle sale involving an imposter led to a replevin case; Supreme Court ruled in favor of good-faith buyer Ledesma, affirming valid title despite dishonored check.

Case Summary (G.R. No. 86051)

Petitioner

Jaime Ledesma claimed to have purchased the 1977 Isuzu Gemini in good faith for valuable consideration and was in possession of the vehicle when Citiwide Motors instituted replevin.

Respondent

Citiwide Motors, Inc. sought recovery of the vehicle by replevin after discovering the instrument of payment had been fraudulently altered and the purchaser was an impostor; Citiwide also pursued damages against the replevin bond and for wrongful seizure.

Key Dates

Relevant transactions and litigation events included: the alleged sale and delivery of two motor vehicles on September 27–28, 1977; discovery of the dishonored manager’s check and police investigation thereafter; institution of replevin by Citiwide on November 16, 1977; sheriff’s recovery of the Isuzu on January 23, 1978; trial court judgment dated September 3, 1979 and Final Order June 26, 1980; Court of Appeals decision reversing the trial court on September 22, 1988 with denial of reconsideration December 12, 1988; and the Supreme Court decision on review rendered September 1, 1992.

Applicable Law

Governing law applied by the Supreme Court (decision rendered in 1992) includes the 1987 Constitution as the constitutional framework, and substantive and procedural provisions cited in the decision: Civil Code provisions (notably Article 559 and provisions on formation and effect of sale—Arts. 1475, 1477, 1478, 1390, 1496, 1506, 1191), Revised Penal Code Article 315 (estafa by false pretenses), and procedural rules referenced in the trial court’s Final Order (Rule 57 Sec. 20 and Rule 60 Sec. 10).

Facts

Citiwide sold two new motor vehicles to a person representing himself as Jojo Consunji. Delivery occurred on September 28, 1977 and the impostor issued Manager’s Check No. 066-110-0638 for P101,000.00. The check was dishonored because the amount had been altered from P101.00 to P101,000.00. Investigation revealed the impostor’s real identity to be Armando Suarez, a known perpetrator of estafa by similar means. Citiwide recovered one vehicle (the Holden) but the Isuzu Gemini ended up in the possession of Jaime Ledesma, who asserted he bought it in good faith from Pedro Neyra. Citiwide filed replevin and, after posting bond, recovered the vehicle by sheriff’s return. At trial the court found Ledesma to be an innocent purchaser for value in good faith and awarded him compensatory damages against the replevin bond and damages for wrongful seizure; the Court of Appeals reversed, holding Citiwide was unlawfully deprived and therefore could recover the vehicle under Article 559.

Procedural History

The trial court (Court of First Instance, later RTC) ruled for defendant Ledesma, ordered return of the vehicle to him, and awarded damages against plaintiff’s replevin bond and for wrongful issuance of the writ. The Court of Appeals reversed, applying Article 559 and finding Citiwide was unlawfully deprived by the impostor’s fraud, thereby stripping Ledesma of the protection of good-faith acquisition. The Court of Appeals denied reconsideration. Ledesma petitioned to the Supreme Court, which reviewed whether Citiwide had been unlawfully deprived so as to make Article 559 applicable and whether title had passed to subsequent purchasers in good faith.

Issues Presented

(1) Whether Article 559 of the Civil Code applied so as to permit Citiwide to recover the vehicle notwithstanding Ledesma’s good-faith purchase for value; and (2) whether the sale to the impostor produced a void or a voidable title such that subsequent purchasers in good faith could obtain valid title absent a prior judicial annulment.

Supreme Court Holding

The Supreme Court set aside the Court of Appeals decision and reinstated the trial court judgment and Final Order. It held that the sale between Citiwide and the impostor resulted in a perfected, unconditional contract of sale and that Citiwide voluntarily transferred possession and the certificate of registration to the vendee (albeit through an impostor). Consequently, title passed on delivery; the subsequent dishonor of the check constituted failure of consideration but did not render the contract void ab initio. The impostor’s title, at most, was voidable for fraud and remained effective until annulled by competent court action. Therefore, Ledesma, who purchased in good faith for value and without notice of defect, acquired title; Article 559 did not operate to divest him because Citiwide was not “unlawfully deprived” in the legal sense required for that exception to apply.

Reasoning and Legal Analysis

  • The Court reiterated the three requisites for possession of movables to be equivalent to title: good-faith possession, voluntary transfer by the owner, and possession in the concept of owner. The case turned on whether Citiwide had been unlawfully deprived of the vehicle.
  • The Court of Appeals characterized the facts as estafa by false pretenses, concluding unlawful deprivation, and applied Article 559’s exception that the owner who has been unlawfully deprived may recover the thing even from a good-faith possessor. The Supreme Court rejected this application.
  • The Court relied on Civil Code provisions governing perfection of sale (Arts. 1475, 1477, 1478). A consensual contract of sale is perfected upon meeting of the minds as to the th

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