Facts:

The case of Manuel Aldeguer et al. vs. Henry Hoskyn revolves around a dispute over land ownership. The plaintiffs, Manuel Aldeguer and others, are the heirs of Doña Petrona Inarda, who purchased the land in question from Don Pablo Garcia in 1855. Doña Petrona resided on the property until her death in 1876, at which point Don Manuel Aldeguer was appointed guardian of her four children, the current plaintiffs. In 1884, Don Manuel sold the land to a certain Martinez, who subsequently transferred ownership to the defendant, Henry Hoskyn, in 1887. The court's findings indicate that the only evidence of Don Manuel's title to the land was his declaration in the deed of sale to Martinez, stating that he had acquired the property from Don Pablo Garcia twenty-four years prior. The defendant, Hoskyn, contested the court's reliance on parol evidence to establish the existence of the sale between Don Pablo and Doña Petrona, arguing that no documentary evidence was presented. ...

Facts:

Transaction History

• Doiia Petrona Inarda purchased the land in 1855 from Don Pablo Garcia.
• After the purchase, Dona Petrona occupied the land until her death in 1876.
• Upon Dona Petrona’s death, her grandfather, Don Manuel Aldeguer, was appointed guardian of her four children—the present plaintiffs.

Subsequent Conveyances

• In 1884, Don Manuel Aldeguer sold the property to one Martinez.
• Martinez, in turn, transferred the land to Henry Hoskyn, the defendant, in 1887.
• In the deed delivered to Martinez, Don Manuel stated that he had acquired the land by purchase from Don Pablo Garcia twenty-four years prior.

Evidence on Title and Contract

• The sole evidence indicating Don Manuel’s title to the land was his declaration in the deed to Martinez.
• There existed an alleged written contract of sale between Don Pablo Garcia and Doiia Petrona, which was not presented in documentary form, as the instrument had been destroyed along with other papers.
• The court based its findings on:
• The preliminary proof of the contract’s existence through its record in the property registry and its inclusion in a complaint filed in 1892 by the plaintiffs.
• Parol evidence, received subsequently pursuant to Section 284 of the Code of Civil Procedure, detailing the contents of the destroyed contract.

Disputed Legal Points

• The defendant asserted that the judgment was improperly supported by parol evidence alone regarding the contract between Don Pablo and Doiia Petrona.
• The appellant raised a claim of acquiring the title by prescription. However, this defense was not timely raised in his answer.
• A motion for a new trial was filed by the appellant on the ground of newly discovered evidence stating that Bonifacio Garcia was never the owner of the property and did not sell it to the plaintiffs’ mother.

Issue:

• Whether the judgment was adequately supported by the established findings of fact, with particular emphasis on the use of parol evidence to prove the existence and contents of the contract of sale.
• Whether the erroneous reliance on parol evidence, given that no documentary evidence of the contract was submitted, constitutes reversible error.
• Whether the defendant’s claim of acquiring title by prescription should have been considered, noting that such a defense was not properly raised in his answer.
• Whether the newly discovered evidence concerning Bonifacio Garcia’s lack of ownership would have had a probable effect on the outcome of the case.
• Whether the record indicates any procedural missteps regarding the naming of Bonifacio Garcia in the plaintiffs’ complaint, and if relevant, whether an amendment of the complaint should have been allowed.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)