Facts:

The case involves the Testate Estate of Perpetua A. Vda. de Soriano, with Dolores Albornoz and Jose Albornoz serving as co-special administrators and opposing parties against Elias Racela, the claimant and appellant. The events leading to this appeal began with two claims presented by Racela against the estate of the deceased Perpetua A. Vda. de Soriano, which were dismissed by the trial court. The first claim was based on a purported sale of one hectare of land for P1,000 executed by the decedent on July 18, 1933, in favor of Racela. The second claim involved another supposed sale of a different parcel of land for P1,000, made on September 23, 1933. These transactions were documented in two deeds marked as Exhibits "A" and "B."

Subsequent to these alleged sales, the decedent sold the same parcels of land in 1934 to Soriano Ballesteros, who successfully registered the deed of sale. Racela attempted to register the deeds executed in his favor, but the de...

Facts:

Parties and Background

• The decedent in the case is Perpetua A. Vda. de Soriano, whose testate estate is in issue.
• Elias Racela is the claimant-appellant alleging entitlement to a sum based on supposed prior transactions.
• Dolores Alibornoz and Jose Alibornoz serve as co-special administrators and oppositors in the civil action.

Alleged Transactions

• Two purported sale transactions were executed by the decedent:
• The first alleged sale involved a one-hectare parcel of land purportedly sold for P1,000 on July 18, 1933.
• The second alleged sale concerned another parcel of the decedent’s land, also allegedly sold for P1,000 on September 23, 1933.
• The sales were documented in two deeds recorded as Exhibits “A” and “B”.

Subsequent Developments

• In 1934, the decedent sold the same parcels of land to a third party, Soriano Ballesteros, who succeeded in registering his deed of sale.
• Elias Racela attempted to register the deeds executed in his favor but was obstructed by the decedent.
• Claimant then initiated a criminal action against the decedent for estafa (Criminal Case No. 6406) based on these transactions.

Criminal Proceedings and Trial Court Findings

• The criminal trial court examined the deeds (Exhibits “A” and “B”) and additional evidence, including oral testimony and financial records.
• The court found that Elias Racela had not delivered any money to the decedent as payment for the alleged sale.
• Evidence suggested that the deeds were executed by the decedent solely to create the impression among neighbors that she had the capacity to dispose of her property.
• Consequently, the trial court acquitted the decedent of the estafa charge by holding that no bona fide sale or payment occurred.

Civil Action and Subsequent Dismissal

• Despite the acquittal in the criminal case, Elias Racela pursued a civil claim seeking P2,000 based on the alleged sales.
• The trial judge, after considering the criminal judgment and the inconsistencies in the claimant’s evidence (particularly the substitution of Exhibit “C” with oral testimony), dismissed the civil action.
• The dismissal was grounded on the reasoning that the acquittal’s declaration—confirming that the alleged sale did not occur—effectively barred the civil claim.

Issue:

• Whether the criminal judgment acquitting the decedent, which established that no sale took place, constitutes a judicial declaration that the fact giving rise to the civil claim did not exist.
• Whether the execution of the deeds (Exhibits “A” and “B”) could be construed as valid evidence of a sale, or if they were merely simulatory instruments to suggest that the decedent had disposed of her property.
• Whether Elias Racela presented sufficient credible evidence to substantiate the claim that an actual sale occurred and that payment was rendered.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)