Petitioner
Walter Easton
Respondent
E. Diaz & Company
Citation
G.R. No. 10012
Court
Supreme Court En Banc
Division
En Banc
Ponente
Torres, J.
Decided
November 9, 1915

Summary

This 1915 Supreme Court case involved a dispute over ownership of an ilang-ilang distillation apparatus. Walter Easton claimed he purchased the still from Jose Parlade on December 15, 1912, but creditor E. Diaz & Company attached it in October 1913 as Parlade's property to satisfy a debt. The Supreme Court reversed the trial court's finding in favor of Easton, ruling that the alleged sale was simulated to defraud creditors. The Court applied Civil Code provisions requiring delivery for ownership transfer and rules on probatory value of private instruments. Key evidence included the still never being delivered to Easton, Parlade's continued possession and deliberate concealment of the apparatus, and the late presentation of the sale document. The decision established important precedents on property ownership requirements and protection of creditor rights against fraudulent transfers.

Statutes applied

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By Intellegal Editorial Board · November 9, 1915

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