Case Digest (G.R. No. 1752)
Facts:
The case, Nicasio Capule vs. Evaristo Capistrano, was decided on February 26, 1906, under G.R. No. 1752. The plaintiff, Nicasio Capule, initiated an action against the defendant, Evaristo Capistrano, to recover possession of a specific tract of land which he claimed to have purchased from Eduardo Capistrano, the defendant's deceased relative. This case arose from a factual dispute over the rightful ownership and possession of the said land. Capule contended that he had taken possession of the property prior to Eduardo Capistrano's death and was subsequently unlawfully deprived of it by the defendant, who claimed ownership as an heir. During the lower court proceedings, the trial judge found in favor of Capule, determining that he had legitimately purchased the property in question and supported his claim with testimonies from four witnesses, alongside a document that evidenced the sale. The defendant's counsel argued that the sale document was not produced in eviden
Case Digest (G.R. No. 1752)
Facts:
- Parties Involved
- Plaintiff and Appellee: Nicasio Capule
- Defendant and Appellant: Evaristo Capistrano
- Nature of the Action
- Action to recover possession of a tract of land as described in the complaint.
- Action includes a claim for damages due to the alleged unlawful detention of the land.
- Transaction and Possession Details
- The plaintiff purchased the land from Eduardo Capistrano, who was deceased at the time of the appeal.
- The plaintiff took possession of the land prior to the death of Eduardo Capistrano.
- After Eduardo Capistrano’s death, the defendant, who claims as heir at law, allegedly wrongfully took possession of the land.
- Presentation of Evidence
- The trial court's findings, as reflected in the bill of exceptions, declared that the transfer was proven by a documentary evidence of sale.
- The document evidencing the sale was corroborated by the testimony of four witnesses.
- The defendant, in his appellate brief, later argued that the document was not produced in evidence; however, this assertion was introduced for the first time on appeal and lacked supporting affidavits or other corroborative evidence.
- Claims and Relief Sought
- The plaintiff sought recovery of the land based on his rightful possession through purchase.
- The plaintiff also claimed damages for the period of unlawful detention by the defendant.
- The trial court, and ultimately the appellate court, had to address both the issue of possession and the substantiation of the claimed damages.
Issues:
- Possession and Title Validity
- Whether the trial court correctly determined that the plaintiff had lawfully purchased the land from Eduardo Capistrano.
- Whether the plaintiff’s taking possession prior to Eduardo Capistrano’s death established his right to the land despite the defendant's claim as an heir.
- Evidence and Admissibility
- Whether the documentary evidence of sale, as produced and corroborated by four witnesses, sufficed to prove the transfer of title.
- Whether the defendant's belated argument regarding the alleged non-production of the document should be considered, given that it was raised for the first time in the appellate brief without supporting evidence.
- Claim for Damages
- Whether the evidence introduced at trial supported the plaintiff’s claim for damages.
- Determining if the damages award should be sustained or reversed based on the evidence presented.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)