Title
Chanco vs. Madrilejos
Case
G.R. No. 1465
Decision Date
Nov 17, 1905
A property dispute hinges on a forged 1875 receipt; Supreme Court overturns trial ruling, citing paper's 1880s origin and chemical aging as proof of fraud.
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Case Summary (G.R. No. 1465)

Introduction of Newly Discovered Evidence

  • The court has the authority to appoint a commissioner to take testimony when a motion for the introduction of newly discovered evidence is presented.
  • The testimony collected by the commissioner will be considered alongside the existing evidence in the case.

Findings of the Trial Court

  • The trial court's judgment was based on the authenticity of a document labeled as Exhibit No. 3, purportedly a receipt from Maximo Madrilejos dated March 1, 1875.
  • The trial court found the document to be genuine, despite the presence of suspicious circumstances surrounding its presentation.

Evidence from the Commissioner

  • A commissioner was appointed to investigate the date of manufacture of the paper used for the alleged receipt.
  • Testimony from Joaquin Samurac, manager of "La Hispana Americana" paper factory, revealed that the paper was produced long after the claimed date of the receipt.
  • The specific watermarks on the paper were exclusive to the factory and were not used until 1880, with the first shipment to the Philippines occurring in 1881.

Allegations of Fraud

  • Evidence presented at trial suggested that the paper had been chemically treated to appear older and that the signature of Maximo Madrilejos was a forgery.
  • The alleged transfer of property indicated by the receipt was determined to be non-existent, establishing the fraudulent nature of the document beyond reasonable doubt.

Trial Court's Reluctance

  • The trial judge expressed reluctance in affirming the document's authenticity, acknowledging the weight of the evidence against it.
  • The judge noted the testimony of witnesses who claimed to have seen the signing of the document, but also recognized the inconsistencies and suspicious circumstances surrounding the case.

Judicial Considerations

  • The judge reflected on the implications of declaring the document a forgery, which would necessitate finding multiple witnesses guilty of false testimony.
  • The judge considered the possibility of reconciling the evidence under the presumption of innocence, ultimately leading to the co...continue reading

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