Facts:

The case involves plaintiff Felix Adan, who initiated legal proceedings against his sister Victoria Adan and her husband Agapito Casili in the Court of First Instance of Camarines Sur. The action sought a judicial partition of the estate of their deceased mother, Simplicia Nepomuceno, which was alleged to include six specific parcels of land. However, since two parcels were deemed irrelevant to the case—one having been sold to the municipality of Libmanan and the other belonging to a half-sister of the litigants—the focus was on the remaining four parcels, collectively valued at P2,783.55. The defendants argued that these four lots had already been ceded to Victoria Adan as her share of the inheritance and contended that Felix had received more than his equitable share through various means, including cash, livestock, and property as support from their mother. The trial court ultimately ruled that the defendants had not satisfactorily proven their claim regarding the supposed do

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Facts:

Parties and Estate Background

• Felix Adan, the plaintiff and appellant, initiated action for judicial partition of the estate of his deceased mother, Simplicia Nepomuceno.
• The estate was originally purported to consist of six parcels of land; however, two parcels were subsequently removed from contention:
• Parcel 1 had been sold to the municipality of Libmanan, Camarines Sur.
• Parcel 3 was acknowledged to have passed to Maria Adan, a half-sibling of the litigants.
• The dispute thus centered on the remaining four parcels, identified in the record as lots Nos. 2, 4, 5, and 6, which both parties valued at P2,783.55.

Claims and Alleged Donations

• The defendants (Victoria Adan and Agapito Casili) maintained that the four parcels in issue had been ceded by the deceased to Victoria Adan as her rightful share.
• The plaintiff contended that, being his due share of the inheritance, he had already received additional benefits in the form of:
• Monetary advances purportedly for his expenses as a student (alleged P8,000.00 from 1918 to 1925).
• Twelve carabaos, valued at P30 each, amounting to P360.00.
• Three hundred cavans of palay, priced at P4.20 per cavan, totalling P1,260.00.
• P1,110.00 in cash taken during an incident involving his mother.
• Proceeds from the purchase of two parcels of land amounting to P1,220.00.
• The trial court, after careful consideration, determined that there was insufficient proof to support the claim that the four parcels were donated to Victoria. Hence, the lots were deemed part of the collated estate.
• The court also held that certain alleged receipts by the plaintiff (specifically, the cash and funds used for purchasing land) were not satisfactorily proven.

Testimonies and Evidentiary Submissions

• The plaintiff failed to testify on his own behalf, placing his entire reliance on the evidence presented by his counsel, Cesareo Fabricante.
• Cesareo Fabricante introduced copies of tax declarations for the disputed parcels and testified regarding the annual produce of lot No. 4, asserting it produced 800 cavans of palay per year.
• The defendant spouses, in contrast, testified in their own behalf, and they were corroborated by another witness, Sisenando Inocencio, regarding:
• The appropriation by the plaintiff of twelve carabaos from his mother's estate.
• The taking of three hundred cavans of palay from his mother's granary in 1927.
• The withdrawal of P1,110.00 from his mother's trunk during a time of her distress.
• The appellate record indicates that the evidence presented by the defendants was not effectively challenged by the plaintiff, as he did not provide any direct testimony to contradict these accounts.

Colation and Computation of the Estate

• The trial court found that:
• The alleged donation of the four parcels to Victoria Adan was unproven due to lack of a written document.
• The money and property transactions alleged by the plaintiff (P1,110 cash and P1,220 for land purchase) were not satisfactorily substantiated.
• However, it did acknowledge that the plaintiff had benefited by receiving:
• P3,000 for his school expenses, with only one-half (P1,500) subject to collation.
• Twelve carabaos valued at P30 each (P360).
• Three hundred cavans of palay, which the court valued at P2.20 per cavan (P660) instead of the amounts claimed by the parties.
• The total credited benefit to the plaintiff was computed at P2,630.00, which exceeded, by P3,120.00, the value of the four parcels assigned to the defendants.

Issues Raised on Appeal

• The plaintiff, on appeal, assigned several errors to the lower court:
• That the evidence proving his receipt of palay, carabaos, and cash was sufficient, which the trial court found otherwise.
• That the testimony regarding the produce of lot No. 4 (800 cavans of palay per year) should have been credited.
• That the lower court erred in omitting the produce (from the time of the mother's death until the suit) in its computation.
• That the computation of the hereditary estate and its partition was erroneous.
• The appellate examination involved an independent review of these assertions and the documentary and testimonial evidence on record.

Issue:

Proof of Donation and Appropriation

• Whether there was sufficient evidence to prove that the deceased had donated the four parcels of land to Victoria Adan.
• Whether the plaintiff’s claim of having received additional benefits (palay, carabaos, and cash) from his mother's estate was substantiated by competent evidence.

Valuation of Produce and Property

• Whether the annual produce of lot No. 4 (claimed at 800 cavans of palay per year) was properly established and should have been included in the calculation of the estate.
• Whether differing valuations assigned by the plaintiff and the defendants (P4.20 versus P2.20 per cavan) affected the fairness of the partition.

Collation and Computation Issues

• Whether the trial court correctly determined which benefits received by the plaintiff should be collated as part of his share of the inheritance.
• Whether the expenditures and gifts relating to the plaintiff’s education and professional training should be collated under articles 1041 and 1042 of the Civil Code.

Evidentiary Adequacy and Credibility

• Whether the plaintiff’s failure to testify personally undermined his case.
• Whether the defendants’ testimonies, and the corroborative evidence presented by their witnesses, were given appropriate weight.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)