Title
Baltazar vs. Alberto
Case
G.R. No. 10557
Decision Date
Jan 29, 1916
Maria Baltazar claims heirship as Julian Baltazar's granddaughter, but Apolonia Alberto proves sole heirship through evidence showing Maria's father was originally Nicolas Olipas, not Baltazar. Court rules for Apolonia.
Font Size:

Case Digest (G.R. No. 10557)

Facts:

    Parties Involved

    • Plaintiffs and Appellants: Maria Baltazar et al.
    • Defendants and Appellees: Apolonia Alberto (alias Basilisa Baltazar) et al.

    Background of the Estate and Probate Proceedings

    • The dispute centers on the estate of the deceased Julian Baltazar.
    • Probate proceedings were concluded in 1911, wherein the estate was awarded to Basilisa Baltazar.
    • Other defendants, being merely tenants on the estate, renounced their interest during the trial.

    Claims Regarding Heirship and Lineage

    • The plaintiff asserts that she is the granddaughter of the deceased Julian Baltazar.
    • The defendant contends that she is, in fact, his only daughter.
    • The dispute thus revolves around the true familial relationships and rightful succession.

    Documentary Evidence and Testimonies

    • Plaintiff’s Evidence
    • Presented a birth certificate indicating that she is the daughter of Nicolas Baltazar and Ambrosia Castillo.
    • The certificate lists her paternal grandparents as Julian Baltazar (the deceased) and Bernabela Andrada.
    • Defendant’s Evidence and Testimonies
    • Testimony asserted that the real surname of Nicolas Baltazar was Olipas.
    • Witnesses testified that Nicolas originally lived outside Urdaneta, Pangasinan, and his first wife, Catalina Sagun, accompanied him there.
    • It was claimed that after the death of Catalina Sagun (his first wife), Nicolas (Olipas) was appointed cabeza de barangay, adopted the surname Baltazar, and subsequently married (allegedly his second wife).
    • Further testimony maintained that Nicolas Olipas was the son of Simon Olipas and Andrada, and that after Simon Olipas’ death, his widow married Julian Baltazar, which produced the defendant.
    • Both parties acknowledged that Nicolas Baltazar married twice, with his first wife being Catalina Sagun.

    Inconsistencies and Conflicting Testimonies

    • The defendant’s witnesses argued that the plaintiff’s claim faced issues because:
    • Their evidence implied that Nicolas Baltazar (or Olipas) had a different familial background from that stated in the plaintiff’s birth certificate.
    • There appeared to be a suggestion of two different individuals named Catalina Sagun and even two separate persons named Bernabela Andrada if the plaintiff’s theory were to hold.
    • The plaintiff’s inability to produce a marriage certificate confirming the union of Nicolas Baltazar with Catalina Sagun further complicated her claim.
    • Both parties admitted discrepancies in the documentary evidence, with birth, marriage, and death certificates under the Spanish regime offering only presumptive evidence of the facts.
    • The conflicting nature of the testimonies raised serious doubts as to the true identity of the parties involved and the legitimacy of the documentary evidence presented.

    Reliance on the Trial Judge’s Findings

    • Given the overwhelming conflicts in documentary evidence and witness testimonies, the trial judge’s direct observation and credibility assessment of the witnesses played a critical role.
    • The trial court drew conclusions regarding which version of events was most credible based on the demeanor and reliability of the witnesses.

Issue:

  • Whether the evidence—both documentary and testimonial—supports the plaintiff’s claim of being the sole heir (as the granddaughter) of the deceased Julian Baltazar.
  • Whether the discrepancies regarding Nicolas Baltazar’s true identity and lineage (including the issue of his surname being Olipas and the details of his marriages) sufficiently undermine the plaintiff’s evidence of familial ties.
  • Whether the trial judge’s findings on the credibility of the witnesses, despite the conflicting evidence, warrant deference on appeal or merit reversal by the appellate court.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is an AI-powered legal research tool in the Philippines with case digests and full jurisprudence. AI summaries highlight key points but might skip important details or context. Always check the full text for accuracy.