Facts:

The case of Jose Antillon vs. Leoncio Barcelon, G.R. No. 12483, was decided on November 16, 1917. The dispute arose over a parcel of land located in the Province of Laguna, Philippines. The plaintiff, Jose Antillon, initiated the action in the Court of First Instance on August 28, 1913, claiming ownership of the land in question. He alleged that the defendant, Leoncio Barcelon, who was the administrator of the estate of the deceased Antonio Bueno, was unlawfully interfering with his possession of the property. Prior to this case, Barcelon had filed a petition in the Court of Land Registration (Cause No. 8350) to have the land registered in his name. Antillon opposed this petition, asserting his ownership of the land. The Court of Land Registration ultimately ruled in favor of Antillon, concluding that he was the rightful owner and that Barcelon was not entitled to the registration. Despite this ruling, Barcelon continued to disturb Antillon's possession of the land. In ...

Facts:

1. Parties Involved:

   • Plaintiff and Appellee: Jose Antillon.
   • Defendant and Appellant: Leoncio Barcelon, Administrator of the Estate of Antonio Bueno, deceased.

2. Subject Matter:

   • The case involves the possession and ownership of a parcel of land described in paragraph 2 of the complaint.

3. Procedural History:

   • The plaintiff filed the action in the Court of First Instance of Laguna on August 28, 1913, alleging ownership of the land and claiming that the defendant was illegally interfering with his possession.
   • The defendant had previously filed a petition in the Court of Land Registration (Cause No. 8350) to register the land in the name of the estate of Antonio Bueno. The plaintiff opposed this petition, asserting his ownership.
   • The Court of Land Registration ruled in favor of the plaintiff, denying the defendant’s petition for registration. Despite this, the defendant continued to interfere with the plaintiff’s possession, prompting the plaintiff to file the present action.

4. Evidence Presented:

   • The plaintiff presented Exhibits E and F, which were documents showing his acquisition of the land from Albino Villegas, who in turn acquired it from Petra Dionido.
   • The defendant objected to the admissibility of these exhibits, arguing that they were not properly identified and that their execution and delivery were not proven.

5. Trial Court Decision:

   • The trial court ruled in favor of the plaintiff, declaring him the owner of the land and awarding him damages of P54 and costs. The defendant appealed the decision.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Public Documents and Notarial Acts:

   • Documents acknowledged before a notary public are considered public documents and are admissible in evidence without further proof of their execution and delivery. This is based on the presumption that notaries public, as public officers, discharge their duties with accuracy and fidelity.

2. Exceptions to Proof of Private Documents:

   • While private documents require proof of their execution and delivery, public documents (such as those acknowledged before a notary public) are exempt from this requirement. This exception is grounded in the need to avoid burdening public officials with constant court appearances.

3. Custody and Identification of Court Records:

   • The clerk of the Court of First Instance, as an ex officio deputy of the General Land Registration Office, is authorized to identify and certify records related to land registration cases, making such records admissible in evidence.

4. Finality of Ownership Claims:

   • The Court upheld the trial court’s finding that the plaintiff had established his ownership of the land through a valid chain of title, and the defendant failed to present sufficient evidence to rebut this claim.