Case Digest (G.R. No. L-8334) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bienvenido Babao, etc. v. Florencio Perez, etc. (102 Phil. 756, decided December 28, 1957), Bienvenido Babao, as judicial administrator of the estate of the late Santiago Babao, sued Florencio Perez, judicial administrator of the estate of the late Celestina Perez, and several purchasers of portions of an unregistered 156-hectare parcel in San Juan, Batangas. The complaint alleged that in 1924 Santiago Babao and Celestina Perez entered into a verbal agreement: Babao would clear, level and plant the forest land at his own expense and administer it during Perez’s lifetime, and in exchange Perez promised to convey one-half of the land, with improvements, to Babao or his wife upon her death. Babao allegedly spent P7,400 on improvements and forfeited a P150 per month salary from 1924 to 1946 (totaling P39,600). Shortly before her death in August 1947, Perez sold 127½ hectares through her attorney-in-fact, Leovigildo Perez, depriving Babao of possession. Babao died in January 1948, Case Digest (G.R. No. L-8334) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Plaintiff-Appellee: Bienvenido Babao, judicial administrator of the estate of the late Santiago Babao.
- Defendant-Appellants: Florencio Perez, judicial administrator of the estate of the late Celestina Perez, and various purchasers of portions of a 156-hectare parcel in San Juan, Batangas.
- Oral Agreement and Improvements
- In 1924, upon his marriage to Maria Cleofe Perez (niece of Celestina Perez), Santiago Babao allegedly agreed verbally with Celestina Perez to:
- Clear and level 156 hectares of forest land; plant thereon coconuts, rice, corn, bananas and bamboo; and administer the land during Celestina’s lifetime at his own expense.
- Receive one-half of the land, with all improvements, upon Celestina’s death.
- Performance by Babao:
- Resigned from a monthly-salary position (P150) to undertake clearing and planting; incurred P7,400 in direct expenses and forewent P39,600 in salary (total P47,000 claimed).
- Planted 5,000 coconut trees on 50 hectares and rice/corn on 70 hectares; administered the land from 1924 until 1946.
- Pre-death sales:
- Shortly before her death in August 1947, Celestina, through attorney-in-fact Leovigildo Perez, sold approximately 127½ hectares.
- Plaintiff alleges these sales were fictitious and in violation of the oral agreement.
- Procedural History
- August 24, 1947: Death of Celestina Perez; intestate proceedings ensued with Florencio Perez appointed administrator.
- January 6, 1948: Death of Santiago Babao; intestate proceedings with Bienvenido Babao appointed administrator.
- Trial Court Judgment:
- Declared the contested sales null and void.
- Ordered conveyance of one-half of the land to plaintiff and payment of annual damages (P3,786.66 with 6% interest).
- Directed survey for division, surrender of possession, and costs.
- Court of Appeals reversed and dismissed the complaint; Supreme Court assumed jurisdiction and remanded but ultimately proceeded to decision.
- On appeal, the Supreme Court considered motions on (a) Statute of Frauds, (b) admissibility of oral evidence, and (c) competency of certain witnesses.
Issues:
- Statute of Frauds
- Does the oral agreement fall under Article 1403(a) (not performable within one year) or 1403(e) (sale of real property interest) requiring a written memorandum?
- Part Performance Exception
- Can Babao’s expenditures and administration “take the case out of the statute” despite lack of writing?
- Admissibility of Oral Evidence Against Deceased
- Are testimonies of Bernardo Babao and Cleofe Perez barred by Rule 123 §26(c) when testifying to pre-death occurrences of Celestina Perez?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)