Facts:

The case of Laurente Baldovino vs. Pedro Amenos et al. revolves around a dispute over the ownership of an 80-hectare tract of land known as the estate of Pangpang, located in Ambos Camarines. The plaintiff, Laurente Baldovino, served as the administrator of the estate of Agustin Lukban de San Miguel, who passed away in 1881. Among the heirs of Agustin Lukban was Vicente Lukban, one of the defendants in this case. The plaintiff claimed that the property belonged to the heirs of the deceased and sought to recover possession from Vicente Lukban and Pedro Amenos.

In 1894, Vicente Lukban initiated proceedings before a justice of the peace to obtain possessory information for the estate of Pangpang and 34 other parcels of land. The justice approved the possessory information on August 21, 1894, and the documents were recorded on September 7, 1894. Vicente claimed ownership of the property, asserting that he had been in possession since 1881, having inherited it from his father. ...

Facts:

Parties and Background

• Plaintiff: Laurente Baldovino, acting as administrator of the estate of Agustin Lukban de San Miguel (deceased).
• Defendants: Pedro Amenos (appellee) and others; Amenos is the principal transferee of the property through subsequent sales.
• Subject Matter: Recovery of possession of an 80-hectare tract of land known as the estate of Pangpang, located in Ambos Camarines.

Possessory Information and Claim of Ownership

• In 1894, Vicente Lukban, one of the heirs of Agustin Lukban, filed a possessory information before a justice of the peace.
• He claimed possession of the Pangpang estate and 34 other parcels, asserting that he had been in possession since 1881, having inherited the property from his father.
• The possessory information was approved on August 21, 1894, and the related documents were recorded on September 7, 1894, thereby creating a presumption of ownership.

Judicial Proceedings and Sale

• The estate had been the subject of prior litigation in the Court of First Instance, where an attachment was ordered against Vicente Lukban.
• On April 22, 1896, following a final judgment in these proceedings, the estate was attached and then sold at a judicial sale.
• Vicente Lukban executed a deed of conveyance to Ildefonso Moreno on December 24, 1896, which was recorded on January 2, 1897.
• Immediately thereafter, on January 4, 1897, Ildefonso Moreno sold the estate to defendant Pedro Amenos, and the deed was recorded on January 21, 1897.

Evidence of Ownership and Subsequent Transactions

• The chain of title shows that Vicente Lukban, who was in possession and had established a record through the possessory information, is the source of the title that eventually passed to Amenos.
• The judicial sale and the subsequent recording of deeds provided prima facie evidence of valid transfer of ownership.
• Testimonies and documents, including contracts and earlier judicial acts, reinforced the claim that the property had been treated as the exclusive possession of Vicente Lukban at the time of sale.

Plaintiff’s Evidence and Contradictory Testimonies

• The plaintiff attempted to overcome the prima facie evidence by presenting a copy of the will of Agustin Lukban de San Miguel.
• The will, however, did not describe the estate in specific terms and left ambiguities regarding the partition of the property among the heirs.
• Testimonies from witnesses such as Esteban Calleja and Juan Pimentel supported Vicente Lukban’s assertion of ownership, while only Vicente Lukban among the heirs testified regarding the division of the estate.
• The inconsistencies in the representation of ownership and the lack of evidence on any partition among heirs rendered the plaintiff’s evidence insufficient.

Contract of Administration and Relevant Legal Provisions

• A contract of administration dated April 7, 1896, between Vicente Lukban and Pedro Amenos indicated that the latter acted as administrator of the estate.
• The plaintiff raised an issue based on Article 1459 of the Civil Code, which prohibits agents from purchasing the property for which they serve as administrators.
• The court scrutinized whether Amenos’s acquisition of the property from a judicial sale (mediated initially by Ildefonso Moreno) was affected by this provision.
• There was no evidence of any direct or implied agreement between Amenos and Moreno that would invoke the prohibition against an administrator purchasing the estate.

Newly Discovered Evidence

• After the initial decision, the appellant sought a new trial based on newly discovered evidence concerning the judicial sale and contracts.
• The new evidence indicated that Vicente Lukban was present at the first judicial sale, that the sale was initially to Manuel de la Portilla, and that subsequent actions led to Ildefonso Moreno’s involvement.
• Despite these admissions, the record did not support any evidence of collusion or a fictitious execution of contracts involving Amenos.

Issue:

• Whether defendant Pedro Amenos acquired a valid title to the estate of Pangpang through the chain of judicial sales and subsequent transfers.
• Whether the possessory information filed by Vicente Lukban, and its subsequent record, sufficed to establish a prima facie presumption of ownership.
• Whether the plaintiff's evidence, particularly the copy of Agustin Lukban’s will and the ambiguous testimony regarding estate partition, was sufficient to challenge the established chain of title.
• Whether the contract of administration between Vicente Lukban and Amenos, in light of Article 1459 of the Civil Code, should have precluded Amenos from purchasing the property.
• Whether the absence of evidence regarding the partition of the estate among the heirs invalidated the plaintiff’s claim that a proper division was never effected.
• Whether any agreement existed between Ildefonso Moreno (as the initial buyer) and Amenos that could have rendered the judicial sale or subsequent transfer invalid under the law.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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