G.R. No. L-18536. March 31, 1965 (Case Brief / Digest)

### Title:
**Teodoro Santos vs. Jose B. Aznar: A Case of Recovery of Possession under Philippine Civil Law**

### Facts:
The case began when Teodoro Santos advertised the sale of his FORD FAIRLANE 500 in May 1959. An individual named L. De Dios, claiming to be acting on behalf of his uncle Vicente Marella, expressed interest in purchasing the vehicle. Despite initial transactions being carried out in good faith, the sale resulted in Marella unrightfully acquiring the car through deceit, by not paying the agreed price and later selling the car to Jose B. Aznar for P15,000.00, without Santos’ consent.

Aznar, believing he acquired the car in good faith, encountered legal disputes when Santos reported the car as unlawfully taken, leading to its seizure by the Philippine Constabulary. Aznar, seeking to reclaim the car, filed a complaint for replevin, which led to Santos’s intervention in the proceedings. The trial court ultimately ruled in favor of Santos, prompting Aznar’s appeal on purely legal questions.

### Issues:
1. Among Teodoro Santos and Jose B. Aznar, who holds the better right to the possession of the disputed automobile?
2. The applicability of Article 559 versus Article 1506 of the New Civil Code of the Philippines concerning the transfer of ownership of movable property acquired in good faith.

### Court’s Decision:
The Supreme Court found in favor of Teodoro Santos (intervenor-appellee). The pivotal consideration was the application of Article 559 of the New Civil Code, rather than Article 1506 as contended by Aznar. The Court clarified that Vicente Marella had no legal title to sell the car to Aznar as the vehicle was never rightfully delivered to Marella; he unlawfully obtained possession through deception. Since Santos had been unlawfully deprived of his property, he was entitled to recover it, notwithstanding Aznar’s good faith acquisition.

### Doctrine:
The Supreme Court reasserted the principle under Article 559 of the New Civil Code that the possession of movable property acquired in good faith is equivalent to title, yet an owner unlawfully deprived of their property may recover it from the current possessor. Importantly, it specified that the true owner’s right to recover their property does not require compensating the possessor who acquired it in good faith unless the property was acquired at public sale.

### Class Notes:
– **Article 559 of the New Civil Code:** Right of the owner to recover possession of movable property unlawfully deprived, overriding the good faith acquisition by another party.
– **Article 1506 versus Article 559:** Article 1506 applies when the seller has a voidable title, not when they lack title entirely, making Article 559 the relevant provision in cases of unlawful deprivation.
– **Ownership Transfer Principles:** Ownership and other real rights over property are not transferred by contract merely but by tradition or delivery (Article 712, Civil Code).
– **Equitable Principles versus Statutory Provisions:** In Philippine jurisprudence, statutory provisions prevail over common law principles in cases of conflict.

### Historical Background:
This case exemplifies the legal challenges surrounding the acquisition of property and the complexities of recovering unlawfully obtained goods. It delineates the Philippine legal framework’s prioritization of statutory provisions over common law principles, specifically in the context of property law and the safeguarding of ownership rights against deceitful transactions.


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