G.R. No. 127745 - Sanson vs. Court of Appeals

On February 7, 1990, Felicito G. Sanson filed Special Proceedings No. 4497 before the RTC of Iloilo City for the settlement of the estate of Juan Bon Fing Sy (d. January 10, 1990), claiming a debt of ₱603,000.00.
His sister, Celedonia Sanson-Saquin, claimed ₱360,000.00 from the same estate.

Petitioners Angeles A. Montinola and her son Eduardo A. Montinola, Jr. later filed separate claims of ₱150,000.00 and ₱50,000.00, respectively.
By order of February 12, 1991, Branch 28 of the RTC appointed Melecia T. Sy (surviving spouse) as administratrix and issued letters of administration.

Creditors testified about pre-death loans evidenced by checks issued by the decedent, which were later dishonored due to account closure.
Administratrix objected under Section 23, Rule 130 (Dead Man’s Statute) to the admission of testimonial evidence by parties or persons acting on their behalf.

Sanson, Celedonia, and Jade Montinola (wife of claimant Eduardo) testified to the genuineness of checks and related transactions; documentary exhibits (checks and return slips) were offered.
Administratrix denied knowledge of the claims, alleged payment, usury, prescription, and challenged both witness competence and exhibit admissibility.
On December 8, 1993, the RTC held the Dead Man’s Statute inapplicable, admitted the evidence, and ordered payment of the claimed amounts from the estate.

The administratrix appealed, alleging four errors including failure to pay filing fees, prescription, witness incompetence under the Dead Man’s Statute, and exhibit inadmissibility.
On May 31, 1996, the Court of Appeals set aside the RTC order and dismissed all claims for want of competent evidence. Its December 9, 1996 resolution denied reconsideration.
Claimants filed a Rule 45 petition before the Supreme Court, assigning errors regarding witness competency and inter-party testimony under the Dead Man’s Statute.

Whether Jade Montinola’s testimony and documentary checks sufficiently proved the Montinolas’ claims in the absence of contrary evidence from the administratrix.
Whether the testimonies of Sanson and Celedonia, each testifying to the other’s claim, are barred by the Dead Man’s Statute.