Title
Aldamis vs. Leuterio
Case
G.R. No. L-3587
Decision Date
Oct 2, 1907
Plaintiff sued defendant for unlawful possession of his hemp estate, claiming damages. Court ruled defendant liable for profits from two months' possession, rejecting de facto government defense. Damages reduced due to insufficient evidence.
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Case Digest (G.R. No. L-3587)

Facts:

Background of the Case

The plaintiff, Francisco Aldamis, filed a lawsuit in the Court of First Instance of Mindoro against the defendant, Faustino Leuterio, seeking damages amounting to 50,400 pesos. The claim arose from the defendant's alleged unlawful possession and operation of the plaintiff's hemp estate in Pola, Mindoro, for nearly a year.

Admitted Facts

  • The defendant admitted to taking possession of and working the plaintiff's hemp estate without consent during 1898.
  • The defendant's possession lasted for approximately two months and a quarter, from late October 1898 to early January 1899.

Disputed Facts

  1. Duration of Possession: The plaintiff claimed the defendant was in possession from November to April, while the defendant argued it was only for about two months and a quarter.
  2. Amount of Hemp Produced: The plaintiff testified that his estate produced an average of over 200 piculs of hemp per month. The defendant, however, presented a document claiming the estate produced less than 40 piculs during his possession. This document was disputed due to inconsistencies with witness testimonies.

Evidence Presented

  • The plaintiff provided testimony and witness statements supporting his claims.
  • The defendant submitted an account of workmen and hemp production, which was challenged for inaccuracies.
  • Seventeen witnesses testified about their work on the estate, with some discrepancies noted in the defendant's records.

Damages Claimed

  • The plaintiff sought damages for the hemp taken and for the deterioration of the estate during the defendant's possession.
  • The court found insufficient evidence to support the claim for deterioration damages, as the defendant was only in possession for a short period.

Defendant's Defense

  • The defendant argued that he acted under the authority of a de facto government established during the insurrection against Spanish rule.
  • He claimed that his actions were lawful as a municipal officer under the revolutionary government.

Issue:

  1. What was the duration of the defendant's unlawful possession of the plaintiff's hemp estate?
  2. What was the amount of hemp produced during the defendant's possession, and what is the corresponding value?
  3. Is the defendant liable for damages due to the deterioration of the estate?
  4. Does the defendant's claim of acting under a de facto government absolve him of liability?

Ruling:

The court ruled in favor of the plaintiff, Francisco Aldamis, but reduced the damages awarded. The key rulings were:

  1. The defendant was in possession of the estate for approximately two months and a quarter.
  2. The estate produced 200 piculs of hemp per month during the defendant's possession, with a total value of 6,600 pesos. After deducting the amount delivered to workmen and the 10 piculs returned to the plaintiff, the defendant was liable for 2,070 pesos.
  3. The plaintiff's claim for damages due to the deterioration of the estate was denied due to insufficient evidence.
  4. The defendant's defense of acting under a de facto government was rejected. The court held that such actions did not absolve him of liability.

Ratio:

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