JOSE R.

CRUZ, PARTIES: RULING

plaintiff-appellant, Pet. Jose Cruz
vs. Res. ART. 559. The possession of movable property acquired in
REYNALDO o Reynaldo Pahati good faith is equivalent to a title. Nevertheless, one who has
PAHATI, ET AL., o Felixberto Bulahan lost any movable or has been unlawfully deprived thereof, may
defendants- o Jesusito Belizo recover it from the person in possession of the same.
appellees.
If the possessor of a movable lost or of which the owner has
PROPERTY: Car
been unlawfully deprived, has acquired it in good faith at a
HOW THE CASE STARTED: public sale, the owner cannot obtain its return without
 Cruz filed an action of replevin against Reynaldo Pahati reimbursing the price paid therefor.
et al for the recovery of possession of an automobile
and certain amount as damages and attoryney’s fees o Plaintiff has a better right to the car in question than defendant
resulting from his illegal deprivation thereof
Bulahan for it cannot be disputed that plaintiff had been illegally
 Pahati admitted having bought the automobile from
deprived thereof because of the ingenious scheme utilized by
Bulahan, for the sum of P4,900 which he paid in check. Belizo to enable him to dispose of it as if he were the owner
 When the Manila Police Department impounded the thereof
automobile, he cancelled the sale and stopped the o Plaintiff therefore can still recover the possession of the car
payment of the check and as a result he returned the
even if defendant Bulahan had acted in good faith in purchasing
automobile to Bulahan who in turned surrended the
it from Belizo.
check for cancellation.
o If Bulahan had been more diligent he could have seen that the
 Bulahan on his part claims that he acquired the
pertinent portion of the letter had been erased which would
automobile from Jesusito Belizo for value and without
have placed him on guard to make an inquiry as regards the
having any knowledge of any defect in the title of the
authority of Belizo to sell the car. This he failed to do.
latter
o The Court further said: It is a fundamental principle of our law of
 Sequence of ownership of the automobile:
personal property that no man can be divested of it without his
o Originally owned by Nothern Motors Inc., - later
own consent; consequently, even an honest purchaser, under a
sold to Chinaman Lu Dag – sold to Jesusito defective title, cannot resist the claim of the true owner. The
Belizo – sold to Cruz – Belizo offered to sell the maxim that 'No man can transfer a better title than he has
said automobile claiming that he has a buyer for himself "obtain in the civil as well as in the common law."
it
 At the time Cruz was convinced by Belizo to sell the
automobile, Cruz’s certificate of registration was
missing so the plaintiff wrote a letter addressed to the
Motor Section of the Bureau of Public Works for the
issuance of a new registration certificate alleging as
reason the loss of the one previously issued to him and
stating that he was intending to sell his car
 This letter was delivered to Belizo, Cruz also turned over
Belizo the automobile on the latter's pretext that he was
going to show it to a prospective buyer.
 The letter was falsified and converted into an authorized
deed of sale in favor of Belizo by erasing a portion
thereof and adding in its place the words "sold the
above car to Mr. Jesusito Belizo of 25 Valencia, San
Francisco del Monte, for Five Thousand Pesos
 (P5,000)."
 Armed with this deed of sale, Belizo succeeded in
obtaining a certificate of registration in his name on the
same date and also on the same date, Belizo sold the
car to Felixberto Bulahan who in turn sold it to Reynaldo
Pahati, a second hand car dealer.
 These facts show that the letter was falsified by Belizo
to enable him to sell the car to Bulahan for a valuable
consideration.

ISSUE:
Who has better right over the automobile, Cruz or Bulahan?