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Aznar V Yapdiangco

In the case of Aznar v. Yapdiangco & Santos, the Supreme Court ruled that Teodoro Santos had a superior right to his stolen car over Jose Aznar, who purchased it in good faith. The court determined that Marella, who sold the car to Aznar, had no valid title due to the fraudulent circumstances surrounding the transaction. Consequently, the vehicle was awarded back to Santos, affirming the lower court's decision.

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30 views1 page

Aznar V Yapdiangco

In the case of Aznar v. Yapdiangco & Santos, the Supreme Court ruled that Teodoro Santos had a superior right to his stolen car over Jose Aznar, who purchased it in good faith. The court determined that Marella, who sold the car to Aznar, had no valid title due to the fraudulent circumstances surrounding the transaction. Consequently, the vehicle was awarded back to Santos, affirming the lower court's decision.

Uploaded by

patrickfranz.fulgencio
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Aznar v. Yapdiangco & Santos (G.R. No.

L-18536, March 31, 1965)


Facts:
1. Advertisement and Sale Offer:
o In May 1959, Teodoro Santos advertised the sale of his Ford Fairlane 500 in two metropolitan
newspapers.
o A certain L. De Dios responded, claiming to represent Vicente Marella, who was interested in
purchasing the car.
2. Negotiation and Contract Execution:
o On May 29, 1959, Marella agreed to buy the car for ₱14,700 but insisted payment would only be made
after registration in his name.
o The parties proceeded to Atty. Padolina’s office, where a Deed of Sale was executed in favor of
Marella.
o They then registered the car under Marella’s name, but up to that point, payment had not been made.
3. Fraud and Deprivation of Possession:
o Santos instructed his son, Irineo, to hold onto the registration papers until full payment was received.
o Marella convinced Irineo to hand over the documents, claiming he needed to show them to his lawyer.
o He then orchestrated a scheme to steal the car, sending Irineo and De Dios to another location while
an accomplice drove away with the vehicle.
4. Subsequent Sale and Legal Dispute:
o Marella immediately sold the car to Jose B. Aznar for ₱15,000, who acquired it in good faith, unaware
of the fraudulent nature of Marella’s title.
o The Philippine Constabulary seized the vehicle after a report by Santos, leading to Aznar’s replevin suit
against Capt. Yapdiangco (who ordered the confiscation).
o Santos intervened, asserting his rightful ownership, arguing he was unlawfully deprived of the car.
Issues and Rulings:
1. Who has a better right to possession—Aznar or Santos?
- Santos.
• While Aznar acquired the car in good faith, Santos was unlawfully deprived of his property under Article 559
of the Civil Code, allowing owners to recover possessions lost or taken unlawfully.
2. Does Article 1506 (voidable title) apply to Marella’s sale to Aznar?
- No.
• Marella had NO title at all, not even a voidable one.
• Article 1506 applies ONLY if the seller had a voidable title—Marella obtained the car through fraud and theft,
not a legal transfer.
3. Was ownership transferred to Marella upon execution of the Deed of Sale?
- No.
• Ownership requires delivery (Article 712, Civil Code), and mere execution of a contract does NOT transfer
ownership.
• Marella never validly took possession, as he stole the car rather than receiving lawful delivery.
4. Did Aznar’s good faith as a buyer override Santos’ claim?
- No.
• Article 559 protects owners from unlawful deprivation, even against good faith buyers.
• The court ruled that Santos had a superior right over Aznar, despite the latter’s lack of knowledge of the fraud.

Final Ruling:
- Aznar’s appeal DISMISSED.
- Lower court’s ruling AFFIRMED—Vehicle awarded to Santos.

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