Case Summary (G.R. No. 168617)
Factual Background
Prior to initiating this lawsuit, Rivera purchased old machinery from the Lichauco Brothers on January 8, 1912, for the amount of P5,500. Although he received a receipt confirming his purchase, he did not take possession of the items. Shortly thereafter, on February 9, 1912, Ong Che purchased a lot of old iron, machinery, and junk from the Lichauco Brothers for P1,100 and took immediate possession of the materials. When Rivera attempted to claim his items, he discovered that many essential parts of the equipment were missing and were in the possession of Ong Che, who laid claim to them based on his purchase.
Judicial Proceedings and Lower Court's Ruling
Rivera instituted legal action in the Court of First Instance in Manila, asserting that he was the rightful owner of the machinery. The trial court ruled in favor of Ong Che, determining him to be a good-faith purchaser who had lawful possession. Rivera subsequently appealed the decision.
Application of Civil Code
The court's decision emphasized Article 1473 of the Civil Code, which provides that a purchaser who possesses property has a superior title compared to a purchaser who has never obtained possession. Despite Rivera's claim to ownership based on the receipt from Crisanto Lichauco, the court noted the insufficiency of Rivera's proof of ownership, especially given that he had never taken possession of the items.
Ownership and Representation Issues
Confusion regarding the original ownership arose from conflicting testimonies concerning the authority of Crisanto Lichauco to sell the items. While he sold the property to Rivera, testimony suggested the items might belong to Galo Lichauco, creating doubts about Crisanto’s authority as a seller. The evidence indicated that the machinery owned by Lichauco Brothers could have been sold by Faustino Lichauco, thereby questioning the legitimacy of Rivera’s purchase.
Plaintiff's Burden of Proof
The court reiterated that it was Rivera’s responsibility to prove his ownership over the items by a preponderance of the evidence. His failure to present himself as a witness and the absence of crucial witnesses—Galo and Faustino Lichauco—were significant factors that undermined his position. Consequently, the court ruled that absence of evidence from the plaintiff necessitated affirmation of the lower court's judgment in favor of Ong Che.
Continuance Request
Rivera’s counsel requested a continuance to secure the attendance of important witnesses
...continue readingCase Syllabus (G.R. No. 168617)
Case Overview
- The case revolves around a dispute over ownership of machinery and boilers sold by Lichauco Brothers.
- The plaintiff, Marciano Rivera, claims to have purchased certain machinery on January 8, 1912, but did not take possession of it.
- The defendant, Ong Che, purchased a different lot of machinery from Lichauco Brothers on February 9, 1912, and took immediate possession.
Factual Background
- Lichauco Brothers offered for sale old machinery and boilers at their yard in Tanduay, Manila.
- Rivera purchased the machinery for P5,500 and received a receipt from Crisanto Lichauco, indicating his purchase.
- The purchased items included:
- Two complete steam-boilers with chimneys.
- One complete steam motor (15 by 30 inches).
- One pair of twin rice hullers.
- One feeding pump for boilers.
- Rivera did not take possession of the items, which remained in the yard.
- Ong Che later purchased old iron, machinery, and junk for P1,100 and took possession of the materials.
Legal Proceedings
- Upon attempting to take possession of the machinery he believed he purchased, Rivera found that many parts were missing and were claimed by Ong Che.
- Rivera filed a lawsuit to recover the articles, asserting he was the true owner.