G.R. No. 1111 - De Lara vs. De Lara

Felicidad Garcia de Lara, the plaintiff and appellant, appealed a judgment rendered by the Court of First Instance.
The appeal was based on a bill of exceptions purportedly prepared under section 143 of the Code of Civil Procedure but failing to comply with its requirements.
The bill of exceptions was fraught with unintelligible statements, extraneous arguments, and a lack of clarity concerning both the nature of the suit and the rulings of the lower court.

The underlying suit is inferred to be an action for the partition of a tract of land.
The disputed property is described as the undivided half of the hacienda de Angono, located in the Province of Rizal.
This property interest was inherited by the plaintiff and the defendants from their deceased father, Don Eugenio Gonzalez de Lara.
It is noted that the property was originally acquired by Don Eugenio through purchase from Dona Dominga Santa Ana.

The bill of exceptions did not meet the plain directions set out in section 143 of the Code of Civil Procedure, crucially deviating from the strict requirements know in American practice.
The appellate court observed that the bill contained elements—such as baseless arguments and irrelevant matters—rendering it ineffective for preserving error for review.
The failure to raise timely and specific objections during the trial led to the loss of the chance for the appellate court to review the trial court’s rulings.

The lower court declined to partition the property, reasoning that the tract in question was part of an undivided interest.
The suit was deficient because it did not include other persons interested in the property, particularly those holding the remaining undivided half, as required by statute.
Section 183 of the Code of Civil Procedure necessitates that in partition actions, every tenant in common, coparcener, or person with an interest in the real estate must be joined as a party to the suit.

The decision highlighted the importance of adhering to the procedural rules governing objections and exceptions, including the requirement that objections must be raised at the proper time (e.g., by demurrer, answer, or during the trial).
The discussion explains that only objections properly preserved by corresponding exceptions may be reconsidered on appeal.
The ruling also restated the principle that litigations affecting multiple interests must include all concerned parties, to avoid rendering the proceedings ineffectual.

Whether a bill of exceptions that does not conform to the prescribed statutory manner under section 143 of the Code of Civil Procedure can sustain an appeal.
Whether the deficiencies contained in the bill, including unintelligible and irrelevant statements, disqualify it from preserving errors for appellate review.

Whether the partition suit, as presented, met the statutory requirements, particularly regarding the inclusion of all interested parties in the action per section 183 of the Code of Civil Procedure.
Whether the court’s refusal to partition the undivided interest was justified on the basis that the necessary parties were not joined, thereby affecting the binding nature of any decree rendered.

Whether the failure to raise timely and specific objections in the lower court effectively precludes the appellate court from addressing alleged errors.
Whether the procedural rule—that objections not properly preserved cannot be raised on appeal—applies strictly in this case.