Title
Chanco vs. Madrilejos
Case
G.R. No. 1465
Decision Date
Nov 17, 1905
Newly discovered evidence of forgery reverses the trial court's judgment, awarding property possession to the plaintiff administrator.
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Case Digest (G.R. No. 1465)

Facts:

  • Alfredo Chanco, administrator of Maximo Madrilejos' estate, is the plaintiff and appellant.
  • Anacleta Madrilejos and others are the defendants and appellees.
  • The case centers on Exhibit No. 3, a receipt allegedly executed by Maximo Madrilejos on March 1, 1875, in Azagara, Philippines.
  • The trial court initially deemed the document authentic.
  • The plaintiff introduced newly discovered evidence questioning the document's authenticity.
  • A commissioner investigated the paper's manufacture date, leading to testimony from Joaquin Samurac, manager of "La Hispana Americana" paper factory.
  • Samurac stated the paper was produced after March 1, 1875, and the watermarks were not used until 1880.
  • Additional evidence indicated the paper was chemically treated to appear older, and the signature was likely forged.
  • The trial judge expressed doubt about the document's authenticity but ultimately sided with the initial ruling.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the document was not genuine and was a forgery.
  • The newly discovered evidence was sufficient to establish the document's fraudulent nature beyond a reasonable doubt.
  • The court reversed the trial court's judgment, ordering the plaintiff ad...(Unlock)

Ratio:

  • The Supreme Court's decision relied on the evaluation of newly discovered evidence, including expert testimony on the paper's manufacture date.
  • The court noted that the watermarks were not in use until years after the alleged execution date, indicating the document could not have been created at that time.
  • Evidence suggested the paper had been artificially aged, and the signature was likely forged.
  • The initial ruling by the trial court was based on witness credibility re...continue reading

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