Edca Publishing & Distributing Corp. v. The Spouses Leonor

Summary

EDCA Publishing sold books to impostor "Jose Cruz" who paid with bad check and sold 120 books to Santos Bookstore. When the check bounced, EDCA forcibly recovered the books with police assistance. The Supreme Court affirmed that EDCA was not "unlawfully deprived" under Article 559 of the Civil Code because it voluntarily delivered the books pursuant to a valid contract of sale. The non-payment of purchase price did not invalidate the transaction or impair the title acquired by good faith purchasers. The Court emphasized that Cruz obtained defective but voidable title that could be transferred to Santos, who acted in good faith by verifying ownership through the EDCA invoice. The decision protects good faith purchasers of movable property and establishes that voluntary delivery under contract, even with subsequent non-payment, does not constitute "unlawful deprivation" under Article 559. EDCA's remedy lies against the impostor, not innocent purchasers.