Case Digest (G.R. No. 2308)
Facts:
The case of Nieves Araujo et al. vs. Gregoria Celis, decided on April 30, 1906, revolves around the estate of Rosario Darwin Araujo, who inherited a hacienda known as Pangpang and other properties from her mother, Asuncion Araujo y Belen. Rosario married Jose Araujo y Celis, the son of the defendant, Gregoria Celis. Rosario passed away on January 22, 1888, without any descendants or ascendants, leaving behind only collateral relatives, who are the plaintiffs in this case. The plaintiffs claimed to be the nearest relatives and sought to inherit the estate of Rosario, requesting the delivery of the property that she inherited from her mother. The defendant, Gregoria Celis, took possession of the property after the death of her son, Jose Araujo, who died in 1889, a year after Rosario. The defendant acknowledged that the property belonged to Rosario but contended that she had left a will bequeathing all her property to her husband, Jose Araujo. Following Jose's death, the def...
Case Digest (G.R. No. 2308)
Facts:
Inheritance and Marriage:
Rosario Darwin Araujo inherited the hacienda known as Pangpang and other properties from her mother, Asuncion Araujo y Belen. She later married Jose Araujo y Celis, the son of the defendant, Gregoria Celis.Death and Claims:
Rosario died on January 22, 1888, without any descendants or ascendants, leaving only collateral relatives. The plaintiffs, Nieves Araujo et al., claimed to be the nearest relatives and sought to inherit Rosario's estate, specifically the property inherited from her mother.Defendant's Claim:
The defendant, Gregoria Celis, admitted that the property belonged exclusively to Rosario but asserted that Rosario had executed a will bequeathing all her property to her husband, Jose Araujo. Upon Jose's death in 1889 without a will, Gregoria claimed she inherited the property as Jose's legal heir.Trial Court Decision:
The lower court ruled in favor of Gregoria Celis, accepting her claim that Rosario had executed a valid will. The plaintiffs appealed, arguing that the judgment was against the weight of the evidence.Evidence on the Will:
The defendant did not produce the original will but offered secondary parol evidence, claiming the original will had been lost. The plaintiffs objected to this evidence, but the court admitted it.Witness Testimony:
The principal witness, Calixto Delgado, testified that he had seen a copy of Rosario's will during a prior legal proceeding in 1889. However, his testimony was unclear and inconsistent, particularly regarding whether the copy was certified. Additionally, the will allegedly had only two witnesses, which would have made it invalid under the law at the time.Alleged Loss of the Will:
The defendant claimed that the copy of the will was destroyed when insurgents burned the court records in 1899. However, there was no conclusive evidence to prove that the will was among the records burned.Notarial Records:
The court noted that notarial records should have been kept at the notary's residence, not the courthouse, as per the law. This cast further doubt on the defendant's claim that the will was destroyed in the courthouse fire.
Issue:
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Ruling:
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Ratio:
Proof of Loss of the Will:
The defendant's evidence was insufficient to establish the loss of the original will. The testimony of the witnesses was unclear, inconsistent, and failed to meet the legal standard for proving the loss of a document.Admissibility of Secondary Evidence:
Secondary evidence of a lost document is only admissible if the loss of the original is satisfactorily proven. Since the defendant failed to prove the loss, the lower court erred in admitting secondary evidence.Validity of the Will:
The alleged will, if it existed, would have been invalid under the law at the time because it was purportedly signed by only two witnesses, which was insufficient for a valid will.Remand for New Trial:
The case was remanded to the lower court for a new trial to properly determine the validity of the will and the rightful heirs to Rosario's estate.