AZNAR v. YAPDIANGCO- Stolen Goods

True owner has a better right than a buyer in good faith to possession of a stolen good.

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 latter’s 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.

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.