Teodoro Santos vs. Jose B. Aznar (G.R. No.
L-18536, March 31, 1965):
🧠 What’s the case all about?
This case is about a car that was stolen through trickery and later sold to
someone who didn’t know it was stolen. The original owner wants the car
back, but the new buyer claims he bought it in good faith.
🔍 What happened?
Teodoro Santos (the real owner) was selling his Ford Fairlane 500.
A man named L. De Dios pretended to be buying it for his uncle, Vicente
Marella.
Santos agreed to sell the car—but Marella never paid.
Marella tricked Santos, got hold of the car, and sold it to Jose B. Aznar for
₱15,000.
Aznar bought it in good faith, thinking Marella was the real owner.
When Santos found out, he reported the car stolen, and the police seized it.
Aznar sued to get the car back (replevin), but Santos said: That’s my car. I
never got paid and was tricked.
⚖️What were the legal issues?
Who has the better right to the car? Santos (original owner) or Aznar (good
faith buyer)?
Which law applies:
Article 559 (return of property if the owner was “unlawfully deprived”)
or Article 1506 (if someone has “voidable title” and sells something to a good
faith buyer)?
⚖️ What did the Supreme Court say?
The Supreme Court sided with Teodoro Santos. Why?
Under Article 559, if a person is "unlawfully deprived" of their property (like
through fraud or theft), they can get it back—even if the new owner bought it
in good faith.
Marella got the car by lying and cheating, so Santos was unlawfully deprived.
Aznar bought the car in good faith, but that doesn't matter under Article 559.
Good faith only protects the buyer if the property wasn’t unlawfully taken.
📌 Key Legal Takeaways:
Article 559, Civil Code: If a person is unlawfully deprived of personal property
(like through fraud or theft), they can recover it from whoever has it—even if
that person is innocent.
Good faith does NOT protect the buyer if the property was unlawfully taken
from the original owner.
Delivery (tradition) is essential for ownership transfer. No delivery, no
ownership.
Article 1506 doesn’t apply here because Marella didn’t have a voidable title—
he had no title at all.
📝 Class Review Summary:
Legal Point Explanation
Article 559 Protects the real owner if they were tricked or stolen from.
Good faith buyer Can still lose property if the original owner was
"unlawfully deprived."
Santos wins Because he never agreed to fully transfer ownership—the buyer
scammed him.
💡 Bottom Line:
Even if you buy something thinking it’s legit, you can still lose it if it was stolen
or fraudulently taken from the real owner. The law protects the original owner,
not the innocent buyer, in these cases.
