Case Digest (G.R. No. L-11827)
Facts:
In the case of Julian Asido vs. Macario Guzman, Rosalia Reyes, and Jacinto Battung, decided on February 15, 1918, the plaintiff, Julian Asido, sought a judgment for possession of a small parcel of land. He presented a deed of sale executed on October 24, 1914, transferring ownership from Federico Comin to himself, along with a prior deed of sale from Domingo Mallillin, the deceased former owner, to Comin, dated April 24, 1900. This earlier deed was duly registered in the appropriate land registry. The principal defendant, Rosalia Reyes, the widow of Domingo Mallillin, contested the validity of the sale, asserting that the deed did not represent a genuine transaction. She claimed that the arrangement was merely a façade to allow Comin to secure possession of the land on behalf of her husband, who was unable to assert his rights due to the prevailing social unrest at the time. Reyes maintained that she and her husband had continued to possess the land from the execution of th...
Case Digest (G.R. No. L-11827)
Facts:
Background of the Case
- The plaintiff, Julian Asido, filed an action seeking possession of a small parcel of land. He based his claim on two deeds of sale:
- A deed of sale from Federico Comin to himself, dated October 24, 1914.
- A deed of sale from Domingo Mallillin (deceased) to Federico Comin, dated April 24, 1900, which was registered in the proper land registry.
Defendant's Claim
- The principal defendant, Rosalia Reyes (widow of Domingo Mallillin), contested the validity of the 1900 deed of sale. She alleged that the sale to Comin was fictitious and that the deed was executed solely to facilitate Comin's possession of the land on behalf of her husband. This was allegedly done to recover the land from a tenant who refused to vacate, as Mallillin feared asserting his rights due to the unstable conditions in the community at the time.
Possession of the Land
- Rosalia Reyes and her husband, Domingo Mallillin, remained in possession of the land from 1900 until Mallillin's death in 1911. Rosalia continued possession thereafter, claiming exclusive ownership.
Plaintiff's Explanation
- Julian Asido argued that after the sale to Comin, Mallillin and his wife remained on the land as tenants, agreeing to pay one-third of the land's fruits as rent. He presented testimony from several witnesses supporting this claim.
Trial Court's Observation
- The trial judge expressed uncertainty about the evidence, stating that while he was unable to resolve the conflicting testimonies, he leaned toward favoring the defendants' position.
Evidence Presented
- Rosalia Reyes provided no evidence other than her own testimony to support her claim of the sale's fictitious nature. Her testimony was contradicted by multiple witnesses for the plaintiff. The court noted the improbability of her story, given her failure to demand the return or cancellation of the deed during the years before Asido purchased the land.
Issue:
- Whether the deed of sale dated April 24, 1900, from Domingo Mallillin to Federico Comin was genuine or fictitious.
- Whether the plaintiff, Julian Asido, is entitled to possession of the land based on the deeds of sale.
- Whether the oral testimony of Rosalia Reyes is sufficient to overcome the presumption of validity and genuineness of a duly executed and registered public document.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)