G.R. No. 1331 - People vs Macalintal

The case originated from a decision of the Court of Appeals dated September 30, 1954, which affirmed the trial court’s decision on the partition of land based on the second conjugal partnership of the deceased Elias Naval.
The division was such that one-half of the land pertained to Elias Naval's second wife (Dolores Jonsay, defendant-appellant), while the remaining half was equally divided among his surviving children.
The trial court, on September 26, 1956, appointed Pantaleon Panelo, a certified surveyor, as Commissioner to partition the property.

The Commissioner’s survey report contained three “positions,” or alternative proposals, from which the parties could select the area to be conferred as usufruct to the surviving spouse.
On March 8, 1957, defendant-appellant Dolores Jonsay, through counsel, asserted that:

The portions outlined in the Commissioner’s report, particularly those in the first and second positions, were unproductive due to the absence of improvements and poor potential for yield.
Although 120 fruit-bearing coconut trees were noted overall, only 80 were present on the widow’s chosen area and 40 on portions allocated for the plaintiffs, suggesting the widow’s selection should be based on the area where she planted these trees during her conjugal life.

The first position in the Commissioner's report would be more just, advantageous, and beneficial to both parties.
Their argument was supported by the fact that under the first position, the usufruct area would adjoin the portion already adjudicated to the widow in ownership, avoiding a “sandwiched” situation created by the third position.
Awarding the third position would provide the widow with a double advantage since she already had the best portion in ownership.

On March 14, 1957, the trial court promulgated an Order, without providing detailed reasons, awarding the widow the usufruct portion based on the first position of the Commissioner’s report.
The widow filed a motion for reconsideration, objecting to the unproductive nature of the awarded portion and intimating the intention to adduce evidence to bolster her claim.
This motion was denied on March 28, 1957, prompting the widow to appeal, and the case was subsequently certified to the Supreme Court.

The entire case was adjudicated on the basis of pleadings, motions, and written manifestations, with no formal hearings conducted.
Except for the Commissioner’s report, no testimonial or documentary evidence was additionally presented by the parties.

Disregarding the widow’s choice of the third position as her preferred usufruct area as manifested in her pleadings.
Awarding her the usufruct over the portion designated as the first position, contrary to her expressed selection.
Denying her the opportunity to adduce evidence to substantiate her contention that the awarded portion was unproductive and not beneficial for the purpose of supporting her during widowhood.

Whether the trial court’s decision, based solely on conflicting written manifestations without evidence, properly ascertained the factual basis needed to determine the advantageous usufruct arrangement intended by law.