LEDESMA v. CA- Perfected Unconditional Contract of Sale

FACTS:

Citiwide sold 2 cars to a certain Jojo Consunji evidenced by 2 invoices. Upon delivery of the cars, Jojo paid with a Manager’s Check (PhP101,000.00). When Citiwide deposited the check, it was dishonored for being tampered. Amount was changed from 101.00 to 101,000.00.

Citiwide reported the crime to the Phil. Constabulary where he found that Consunji was actually Armando Suarez, a professional criminal.

One car was found abandoned, while the other was discovered to be in the possession of Jaime Ledesma, who claims to have purchased the car in good faith from the registered owner, evidenced by the LTO Registration.

RTC ordered the car to remain in the possession of Ledesma.

CA overruled RTC, stating that Citiwide was unlawfully deprived of property through false pretenses amounting to fraud.

ISSUE:

Whether or not the owner was unlawfully deprived of the property?

HELD:

No. There was a perfected unconditional contract of sale. Failure to pay by Suarez through the subsequent dishonor of the check did not render the contract of sale void. Ownership was already transferred by the delivery of the cars to Suarez.