Facts:

The case of Esteban Arabes and Lucina Estovilo v. Diego Urian et al., decided on October 27, 1906, involved a dispute over the estate of Juan Urian and his wife, Maria Nullen, who passed away intestate. The proceedings for the settlement of their estate commenced in February 1894, initiated by Diego Urian and others in the former Court of First Instance of La Laguna. An inventory of the deceased's properties was ordered, which included 12 tracts of land, 2,000 coconut trees, and 80 cavanes of palay. These properties, claimed by the plaintiffs Arabes and Estovilo, were reportedly part of their inheritance from Urian or were acquired through purchases from him and his heirs. A receiver, Felipe Onrade, was appointed to manage the estate. The plaintiffs asserted their ownership and sought the return of the properties, along with 6,458 pesos for the fruits and earnings derived from them. In its findings, the lower court established that the plaintiffs had adverse possession of th

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Facts:

Background of Estate Proceedings

• The proceedings for settling the estate of Juan Urian and his wife, Maria Nullen, who died intestate, were initiated in 1894.
• The inventory of the estate, which included the contested property, was made in February 1894 at the suggestion of the parties who instituted the intestate proceedings.
• Felipe Onrade was appointed receiver and administrator of the estate, and the inventory included:
• 12 tracts of land;
• 2,000 coconut trees;
• 80 cavanes of palay.

Nature and Claims of the Plaintiffs

• The plaintiffs, Esteban Arabes and his wife Lucina Estovilo, claimed ownership over the property included in the inventory.
• Their claim was based on:
• Purchase of part of the property from Juan Urian;
• Inheritance from the deceased;
• Subsequent purchase from Juan Urian’s heirs.
• They had already recorded possessory information proceedings in the old Registry of Property of the Province of La Laguna evidencing their title.
• Prior to the inventory, they were in adverse possession of the property for a period of three to four years.

Prior Litigation and Recorded Proceedings

• The plaintiffs had instituted an action in the Court of First Instance of La Laguna to have the property excluded from the estate’s inventory.
• The record of such proceedings, along with the records from the intestate proceedings, was lost during the last insurrection.
• Although only Felipe Onrade remained as defendant (with the other defendants Diego Urian and Felix Urian having died), the actions proceeded without prejudice to the rights of the heirs of the deceased.

Judgment of the Court Below

• The court directed the following:
• Felipe Onrade was ordered to cease administering the property and to render an account of his administration according to the law.
• Onrade was further directed to either relinquish possession of the property (including the coconut trees and palay) in favor of the plaintiffs or pay the market value thereof.
• It was reserved that parties interested in the title could further bring actions for ownership recovery and indemnification.
• Costs of the proceedings were to be shared equally between the parties.
• The record included detailed findings that supported:
• The inclusion of the disputed property in the 1894 inventory.
• The adverse possession of the plaintiffs prior to the inventory.
• The existence of recorded possessory information proceedings by the plaintiffs.
• The subsequent action for exclusion of the property from the estate’s inventory.

Assignments of Error Raised on Appeal

• The appellant raised six assignments of error, the notable issues being:
• Questions regarding how the plaintiffs acquired their alleged title (by purchase, by inheritance, and purchase from heirs).
• Whether the plaintiffs’ possessory inscription in the registry constituted valid evidence.
• The propriety of the action for exclusion (tercero) in the Court of First Instance.
• The admittance of secondary testimony as evidence of possessory proceedings.
• The appropriateness of restoring possession to the plaintiffs despite insufficient evidence of title.
• The classification of the case as an action for possession rather than an adjudication of ownership.

Issue:

Sufficiency and Admissibility of Evidence

• Whether the findings of fact regarding the plaintiffs’ acquisition of the property—through purchase, inheritance, and purchase from heirs—were supported by sufficient evidence.
• Whether the recorded possessory proceedings provided adequate proof of the plaintiffs’ right over the property.

Nature of the Proceedings and Action

• Whether the action should be viewed as an action for possession or as an action adjudicating title, thus affecting the required burden of proof.
• Whether an intestate proceeding, by itself, provided sufficient legal ground to displace a party in adverse possession.

Restoration of Possession

• Whether ordering the defendant Onrade to restore possession to the plaintiffs in light of his continued administration since the property’s inclusion in the inventory was legally tenable.
• The implications of adverse possession being a basis for negating the inclusion of the property in the estate inventory.

Weight of Precedential Findings

• Whether the trial court’s reliance on the findings of fact was justified and whether these findings were manifestly against the weight of the evidence.
• Whether the appellate court could revisit facts that had been firmly established by the lower court’s record.

Ruling:

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Ratio:

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Doctrine:

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