Title
Baltazar vs. Limpin
Case
G.R. No. 24636
Decision Date
Mar 25, 1926
Land registration dispute: applicants Baltazar and Limpin sought land ownership, opposed by Bartolome Limpin and the Director of Lands. Referee's report favored applicants, but trial judge partially dissented. Supreme Court ordered transcription of stenographic notes for review.
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Case Digest (G.R. No. 24636)

Facts:

  1. Parties Involved:

    • Plaintiffs and Appellants: Miguel Baltazar and Jacoba Limpin.
    • Defendants and Appellees: Bartolome Limpin and the Director of Lands.
  2. Nature of the Case:

    • Miguel Baltazar and Jacoba Limpin filed an application in the Court of First Instance of Pampanga to register certain parcels of land in their names.
    • Bartolome Limpin and the Director of Lands opposed the application, seeking registration of the lands in their respective names (Bartolome Limpin for himself and the Director of Lands for the Government of the Philippine Islands).
  3. Appointment of Referee:

    • The parties agreed to appoint Mr. Jose Gutierrez David as a referee.
    • The referee inspected the land and submitted a report favorable to the applicants (Baltazar and Jacoba Limpin).
  4. Trial Court’s Decision:

    • No timely or specific exceptions were filed against the referee’s report.
    • The trial judge issued a decision partially concurring with and partially dissenting from the referee’s report.
    • The applicants, who were favored by the referee’s report but not by the trial judge’s decision, appealed.
  5. Appellate Proceedings:

    • The appellee (Bartolome Limpin) filed a motion requesting the transcription of the stenographic notes from the referee’s session.
    • The Supreme Court initially denied the motion but later reconsidered its decision.

Issue:

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Ruling:

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Ratio:

  1. Referee’s Report and Trial Judge’s Discretion:

    • Under Section 140 of the Code of Civil Procedure and Section 36 of the Land Registration Law (Act No. 496), a trial judge has the discretion to accept a referee’s report in part, set it aside in part, or reverse it entirely.
    • However, if no exceptions are taken to the referee’s report and the trial judge confirms it, the findings become conclusive, and the parties cannot dispute their truthfulness.
  2. Importance of Stenographic Notes:

    • The findings of the trial court are ordinarily conclusive if the stenographic notes and exhibits are not presented in the appellate court.
    • In this case, the appellee’s diligence in seeking the transcription of the notes was justified, as the referee’s report was not entirely adopted by the trial judge.
  3. Limitation of Previous Jurisprudence:

    • The principles established in prior cases (e.g., Kriedt vs. E. C. McCullough & Co. and Santos vs. De Guzman and Martinez) apply only when the trial judge confirms the referee’s report without exceptions.
    • These principles do not extend to cases where the trial judge exercises discretion to accept or reject parts of the report.


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