Facts:

In the case of Eduardo Baloloy vs. Jose Edu et al., decided by the Supreme Court of the Philippines on October 19, 1911, the plaintiff, Eduardo Baloloy, initiated legal proceedings on June 12, 1909, against the defendants, Jose Edu and others, in the Court of First Instance of the Province of Ilocos Norte. The objective of the lawsuit was to secure a partition of four parcels of land situated in the sitio of Rincon, pueblo of Bangui, Ilocos Norte. The defendants responded with a general and special answer asserting their exclusive ownership over the first two parcels of land specified in the complaint, claiming that the third and fourth parcels were under the possession of a third party, Maximo Zales, asserting that they had no interest in those parcels and further arguing that the lands were inadequately described in the complaint.

During the trial, the presiding judge, Hon. Dionisio Chanco, made several findings: (a) the parcels of land had already undergone division, making

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Facts:

Commencement of the Action

• On June 12, 1909, Eduardo Baloloy, the plaintiff, initiated an action in the Court of First Instance of the Province of Ilocos Norte.
• The suit sought a partition of four parcels of land located in the sitio of Rincon, pueblo of Bangui, Province of Ilocos Norte.

Defendant’s Answer and Claims

• The defendants filed both general and special answers.
• They claimed exclusive ownership of the first and second parcels of land as described in the complaint.
• They asserted that the third and fourth parcels were in the possession of one Maximo Zales, and that they had no interest in these.
• The defendants contended that the land description in the complaint was not proper.

Evidence Presented at Trial and Findings by the Trial Judge

• The Hon. Judge Dionisio Chanco conducted the trial and reviewed the evidence adduced by both sides.
• The trial judge found that the disputed parcels had already been divided among the parties.
• It was determined that a petition for partition was not the proper remedy in light of the prior division.
• The judge observed discrepancies between the land descriptions in the complaint and the plan submitted by the plaintiff.
• Documentary evidence presented by the defendants clearly indicated that they were in possession of the lands they claimed.

Plaintiff’s Testimony and Documentary Evidence

• The plaintiff testified that in 1869 a mutual agreement had been reached between his parents and the parents of the defendants for the partition of the lands.
• To support his testimony, the plaintiff introduced Exhibit A, an agreement concerning the division of certain parcels of land located in the sitio of Rincon.
• The description of the lands in Exhibit A lacked sufficient detail to conclusively determine if they were the same as those mentioned in the complaint.
• The plaintiff alleged that the lands described in the agreement were identical to those in the present suit.

Reference to a Related Earlier Action

• Documentary evidence indicated that on May 28, 1870, the plaintiff’s parents had initiated an action against the parents of the defendants.
• This 1870 action aimed to recover possession of a parcel of land situated in the same sitio of Rincon and was decided in favor of the defendants’ parents.
• There was no evidence linking the lands involved in this 1870 case to those in the present partition suit.

Emphasis on the Need for Precise Land Identification

• The case highlighted the importance of describing claimed parcels of land with exact metes and bounds and presenting a corresponding plan.
• In disputes over land possession, the courts expect parties to supply definite plans prepared by competent persons.
• The absence of a precise plan makes it challenging for the courts to ascertain the identity of the real property in controversy.

Issue:

• Whether a petition for partition is appropriate when the disputed parcels have already been divided among the parties.
• Whether the lands described in the complaint are sufficiently and accurately identified by metes, bounds, and accompanying plans.
• Whether the documentary evidence, including the historical partition agreement (Exhibit A) and earlier actions, conclusively identifies the lands in dispute.
• Whether the remedy of partition is proper in a situation where alternative legal actions exist for recovering possession of a lost portion.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)