Facts:

This case, Justo Alcaraz et al. vs. Ricardo Racimo et al., was decided by the Supreme Court on October 27, 1983, under G.R. No. L-26746. The plaintiffs-appellees, Justo Alcaraz, Maria Alcaraz, Francisca Alcaraz, Joaquin Alcaraz, Venancio Alcaraz, and Patrocinio Alcaraz, filed a case against defendants-appellants Ricardo Racimo and Cleotilde Racimo. The dispute arose from the partition of certain parcels of land, which had been a joint inheritance from their common ancestors, Romulado Racimo and Petrona Acacio. The couple had two children, Donato and Maria, both of whom had since passed away. The children of Donato were the defendants, while the children of Maria were the plaintiffs.

Romulado Racimo and Petrona Acacio purchased the land in question in 1890. After Romulado's death, Petrona sought a Spanish title for the property, recognizing their ownership. Although the property was originally one whole lot, it was later divided into parcels due to irrigation work done on the

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Facts:

Parties and Procedural History

• Plaintiffs-Appellees: Justo Alcaraz, Maria Alcaraz, Francisca Alcaraz, Joaquin Alcaraz, Venancio Alcaraz, and Patrocino Alcaraz.
• Defendants-Appellants: Ricardo Racimo and Cleotilde Racimo.
• The case originated from a decision of the Court of First Instance of Ilocos Norte ordering the partition of disputed land parcels between the parties, with a subsequent dismissal of the defendants’ counterclaim and a denial of a motion for reconsideration.

Land Description and Title History

• The disputed property originally consisted of one whole lot purchased in 1890 by Romualdo Racimo and Petrona Acacio from Evaristo Malinta.
• The parcel was later subdivided:
• Petrona Acacio, after the death of her husband, secured a Spanish title called Informacion Posesoria before the Justice of the Peace of Vintar, Ilocos Norte in 1891.
• The land was converted into an irrigated ricefield by the “Zanjeros” who, for their work, took 2/3 of the property while 1/3 remained with Petrona Acacio.
• The identification and location of the parcels were undisputed by both parties.

Administration, Harvest, and Dispute Over Shares

• Management of the property:
• Upon Petrona Acacio’s death, Ricardo Racimo (son of Donato Racimo) and Cuadrato Alcaraz (son of Maria Racimo) took over the management of the land.
• The owner’s share of the harvest (after deducting one uyon reserved for tax payment) was historically divided equally among the respective descendants.
• In 1950, a dispute arose when the defendants allegedly refused to give the plaintiffs their corresponding share of the palay harvested from the land, prompting the suit for partition.

Documentary Evidence and Contested Submissions

• Evidence by the Plaintiffs:
• Submission of documentary evidence showing the land purchase, subdivision, and subsequent conversion of the property.
• Testimonies supported the historical division between the “Zanjeros” and Petrona Acacio.
• Evidence by the Defendants:
• Introduction of a document (marked as Exhibit 1 and its translation Exhibit 1-A) purportedly executed by Petrona Acacio in 1902, which allegedly gave Ricardo Racimo the parcels on condition that title would vest upon her death.
• The document was not formally offered as evidence in accordance with the rules of court and was hence not considered by the trial court.

Procedural Developments During Trial

• Death of a Party and Amendment of the Complaint:
• Defendant Ricardo Racimo died during trial, leading the court to order the substitution of his heirs as party-defendants.
• Plaintiffs failed to amend the complaint within the prescribed five-day period but filed an amended complaint on the sixth day. Initially, the amended complaint was dismissed, but later, upon a motion for reconsideration, it was admitted.
• Motion for Postponement and Evidentiary Issues:
• On July 30, 1964, Defendants’ counsel filed a motion to postpone trial on the ground that his witnesses were in Apayao, Mountain Province planting rice.
• The court denied the motion citing the undue delay (the case having been filed over thirteen years earlier) and considered the matter submitted for decision.
• During the hearing of a motion for reconsideration, the Defendants’ counsel indicated a refusal to formally present his exhibits and testimony of witnesses, notably that of Mr. Gamaliel Racimo, resulting in those documents not being entered into evidence.

Trial Court’s Decision

• The trial court ruled that the parcels of land be divided equally “share and share alike” — one-half to the plaintiffs and one-half to the defendants.
• The court dismissed the defendants’ counterclaim and upheld its decision regarding evidentiary procedures (specifically, the non-admittance of exhibits not formally presented).

Issue:

Whether the lower court erred in holding that the properties were owned in common.

• Defendants argued that the characterization of common ownership was mistaken.

Whether the lower court erred in considering the case as submitted for decision after the plaintiffs had presented their evidence and rested their case.

• Defendants contended that the denial of the motion to postpone and the subsequent treatment of the case was improper.

Whether the lower court erred in requiring the substituted defendants to submit their exhibits after the motion for reconsideration was denied.

• The issue arose regarding the admission of previously unoffered documentary evidence.

Whether the lower court erred in admitting the amended complaint despite the initial dismissal when substitution of a deceased party was required.

• Defendants argued that the admission of the amended complaint was procedurally improper.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)