Salvador Panganiban vs Agustin Cuevas 7 Phil 477 Case Digest

Salvador Panganiban vs Agustin Cuevas

Concept:

Article 1240. Payment shall be made to the person in whose

favor the obligation has been constituted, or his successors-ininterest,

or any person authorized to receive it

Facts:

·         Agustin Cuevas was ordered to return the property to Panganiban and to pay the proceedings

·         Dec. 10, 1897. Panganiban was an owner of a Camarin (Nipa and bamboo construction) and lot. He sold it to one Francisco Gonazales in the sum of P1,300. It had a stipulation that the vendor has the right to repurchase within six months from the time of purchase, in compliance with the art 1518 of the civil code, if the vendor fails to do so the vendee will pay P200 and he will be the absolute owner.

·         August 1, 1900. Gonzales sold the property to Agustin Cuevas with the same price. It was also stated that the vendor (panganiban) has the right to repurchase and if in six months he failed to do so the vendee (Cuevas) has to pay P200 and will be the owner.

·         Cuevas asked and granted judicial possession of the property, notice was given to the occupants of the property, among them was the wife of Panganiban. Cuevas paid in court the sum of P200 and declared that he is now owner of the property. The payment was refused by Panganiban and an action of ejectment was filed against Panganiban

·         Panganiban said that In the month of May 1898, He sought to repurchase the property, but he could not locate Gonzales due to the revolutionary war. The revolutionary government then seized the land and camarin from Gonzales. Panganiban redeemed  the property to th erevolutionary government on November 12, 1898  by paying the repurchase price. On the other hand, on August 1, 1900, Gonzales sold the property to Cuevas.

Issue: W/ON the Purchase made by Panganiban from the revolutionary army vested him the right to the property.

Held: No. The property was seized by the army not confiscated, a seizure just prohibits the owner from enjoying his/her property. Panganiban repurchased the property from the army but the army was not the owner. the Supreme Court said that payment made to a third person, even through error and in good faith, shall not release the debtor of the obligation to pay and will not deprive the creditor of his right to demand payment. If it becomes impossible to recover what was unduly paid, any loss resulting therefrom shall be borne by the deceived debtor, who is the only one responsible for his own acts unless there is a stipulation for the wrongful payment.