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    Aznar Vs Yapdiangco

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    Paolo Brillantes
    This case involves a dispute over possession of a stolen vehicle between the true owner and a buyer. The Court held that the true owner has a better right to possession than a buyer, even if the buyer was unaware the vehicle was stolen. Here, a man stole a car by pretending to buy it from the owner's son but never paid. He then sold the car to another buyer. The Court ruled the original owner still had the right to possession, as the thief never acquired valid title, making the second sale invalid. Possession was returned to the original owner.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Aznar Vs Yapdiangco

    Uploaded by

    Paolo Brillantes
    839 views2 pages
    This case involves a dispute over possession of a stolen vehicle between the true owner and a buyer. The Court held that the true owner has a better right to possession than a buyer, even if the buyer was unaware the vehicle was stolen. Here, a man stole a car by pretending to buy it from the owner's son but never paid. He then sold the car to another buyer. The Court ruled the original owner still had the right to possession, as the thief never acquired valid title, making the second sale invalid. Possession was returned to the original owner.

    Original Description:

    Aznar vs Yapdiangco

    Original Title

    Aznar vs Yapdiangco

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    This case involves a dispute over possession of a stolen vehicle between the true owner and a buyer. The Court held that the true owner has a better right to possession than a buyer, even if the buyer was unaware the vehicle was stolen. Here, a man stole a car by pretending to buy it from the owner's son but never paid. He then sold the car to another buyer. The Court ruled the original owner still had the right to possession, as the thief never acquired valid title, making the second sale invalid. Possession was returned to the original owner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    839 views2 pages

    Aznar Vs Yapdiangco

    Uploaded by

    Paolo Brillantes
    This case involves a dispute over possession of a stolen vehicle between the true owner and a buyer. The Court held that the true owner has a better right to possession than a buyer, even if the buyer was unaware the vehicle was stolen. Here, a man stole a car by pretending to buy it from the owner's son but never paid. He then sold the car to another buyer. The Court ruled the original owner still had the right to possession, as the thief never acquired valid title, making the second sale invalid. Possession was returned to the original owner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Aznar vs Yapdiangco

    G.R. No. L-18536 March 31, 1965

    DOCTRINE: True owner has a better right than a buyer in good faith to possession
    of a stolen good. The car was evidently stolen and that the buyer did not acquire
    any valid title thereto.

    FACTS: Teodoro Santos advertised the sale of his FORD FAIRLANE 500 in a
    newspaper. On L. De Dios went to the house of Teodoro and talked to his son Ireneo
    Santos and said that his uncle Vicente Marella is interested in buying the said car.

    The next day, Ireneo went to the house of Marella and they agreed to the price of
    P14,700 on the understanding that it will be paid after the car has been registered
    in the latters name.
    A deed of sale was executed and the registration was changed to the name of
    Marella. Ireneo went to Marella to get the payment and deliver the car who informed
    him that he is P2,000 short of the money and that they need to go to his sister to
    get it. Ireneo, together with De Dios and an unidentified man went to a house.

    Once inside, De Dios asked Ireneo to wait in the sale. After waiting in vain, he went
    down and discovered that the car was gone.

    Marella was able to sell the car to plaintiff-appellant Jose Aznar and while attending
    to registration, the car was seized by Phil. Constabulary due to the report of the
    incident.
    Aznar filed a complaint for replevin against Capt. Yapdiangco of the Phil.
    Constabulary

    ISSUE: Between the two parties, who has the better right?

    HELD:
    Teodoro Santos has the better right. Marella did not have any title to the property
    under litigation because the same was never delivered to him. He may have the
    contract but he never acquired valid title. Although the keys to the car may have
    been given to the unidentified companion, it may be done only because that
    companion took them to the place where the sister of Marella was supposed to live.
    The car was evidently stolen and that the buyer did not acquire any valid title
    thereto.

    In the case on hand, the car in question was never delivered to the vendee by the
    vendor as to complete or consummate the transfer of ownership by virtue of the
    contract. It should be recalled that while there was indeed a contract of sale
    between Vicente Marella and Teodoro Santos, the former, as vendee, took
    possession of the subject matter thereof by stealing the same while it was in the
    custody of the latter's son.

    There is no adequate evidence on record as to whether Irineo Santos voluntarily


    delivered the key to the car to the unidentified person who went with him and L. De
    Dios to the place on Azcarraga where a sister of Marella allegedly lived. But even if
    Irineo Santos did, it was not the delivery contemplated by Article 712 of the Civil
    Code. For then, it would be indisputable that he turned it over to the unidentified
    companion only so that he may drive Irineo Santos and De Dios to the said place on
    Azcarraga and not to vest the title to the said vehicle to him as agent of Vicente
    Marella. Article 712 above contemplates that the act be coupled with the intent of
    delivering the thing.

    The plaintiff-appellant accepts that the car in question originally belonged to and
    was owned by the intervenor-appellee, Teodoro Santos, and that the latter was
    unlawfully deprived of the same by Vicente Marella. However, the appellant
    contends that upon the facts of this case, the applicable provision of the Civil Code
    is Article 1506 and not Article 559 as was held by the decision under review. Article
    1506 provides:
    ART. 1506. Where the seller of goods has a voidable title thereto, but his, title
    has not been voided at the time of the sale, the buyer acquires a good title to the
    goods, provided he buys them in good faith, for value, and without notice of the
    seller's defect of title.

    The contention is clearly unmeritorious. Under the aforequoted provision, it is


    essential that the seller should have a voidable title at least. It is very clearly
    inapplicable where, as in this case, the seller had no title at all.

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