Title
Kiel vs. Estate of Sabert
Case
G.R. No. 21639
Decision Date
Sep 25, 1924
Kiel and Sabert formed a verbal partnership to develop public land; after Kiel's deportation, Sabert transferred rights to a company. Kiel claimed P20,000 from Sabert's estate; Court ruled inadmissible testimony but upheld partnership, remanding for valuation of improvements.
A

Case Summary (G.R. No. 21639)

Factual Background

Albert F. Kiel and William Milfeil began work in 1907 on public lands in Parang, Province of Cotabato, known as the Parang Plantation Company; Kiel subsequently succeeded Milfeil. In 1910 Kiel and P. S. Sabert entered into an agreement pursuant to which Sabert provided capital and Kiel managed development; they agreed to share equally. The partnership arrangement was effected in part because Kiel was a German citizen and could not lawfully take title to public land. Kiel worked upon and developed the plantation from 1910 until 1917. During the World War Kiel was deported. Sabert later joined four others to organize the Nituan Plantation Company on August 16, 1919, and on April 10, 1922 he purportedly transferred all his rights in two parcels to that company for P1. Prior to his death Sabert had written on June 6, 1918 that he would sell all his property for P40,000 or take in a partner willing to develop the plantation. Sabert died before any amicable settlement or final judicial determination between the parties.

Procedural History

The claim of Albert F. Kiel was first presented to the estate commissioners and was disallowed. Kiel appealed and obtained a favorable judgment in the Court of First Instance. The Estate of P. S. Sabert appealed that judgment to this Court. The complaint in the trial court sought a money judgment against the estate for P20,000 and did not allege an interest in land or expressly seek to establish a resulting trust.

Issues on Appeal

The defendant-appellant assigned seven errors, stated in the record as follows: "(1) In finding this was an action to establish a resulting trust in land. (2) In finding a resulting trust in land could have been established in public lands in favor of plaintiff herein who was an alien subject at the same time said alleged resulting trust was created. (3) In finding a resulting trust in land had been established by the evidence in the case. (4) In admitting the testimony of the plaintiff herein. (5) In admitting the testimony of William Milfeil, John C. Beyersdorfer, Frank R. Lasage, Oscar C. Butler and Stephen Jurika with reference to alleged statements and declarations of the deceased P. S. Sabert. (6) In finding any copartnership existed between plaintiff and the deceased Sabert. (7) In rendering judgment for the plaintiff herein."

The Court's Analysis on Resulting Trusts

The Court treated errors one, two, and three together and deemed extended discussion unnecessary. It observed that the complaint sought a straight money judgment and did not assert any legal or equitable title to the land or plead a resulting trust. The Court noted the general rule that a trust will not be enforced when it would serve to evade statutory prohibitions on alien acquisition of real property, and it remarked that the trial judge did not actually rest his decision on a finding that a resulting trust in land had been established but only cited an authority from the Supreme Court of California concerning resulting trusts.

Admissibility of Plaintiff's Testimony

Regarding error four, the Court held the trial court erred in admitting the testimony of Albert F. Kiel concerning events occurring before Sabert's death. The Court relied on Code of Civil Procedure, sec. 383, No. 7, which declares parties to an action against an executor or administrator incompetent to testify as to matters of fact occurring before the decedent's death. The Court distinguished the California decision relied upon by the trial court and cited Maxilom v. Tabotabo as controlling authority that a claimant against an estate is absolutely prohibited from testifying to facts occurring before the death of the decedent.

Admissibility of Declarations of the Deceased

The Court found error five not well taken. It held that testimony as to declarations, acts, or omissions of P. S. Sabert that were against his pecuniary interest or related to his real property were admissible under Code of Civil Procedure, secs. 282 and 298 No. 4. The Court cited Leonardo v. Santiago and concluded that the testimony of the five witnesses concerning Sabert's statements was properly received for whatever probative value it possessed.

Existence of the Copartnership

On error six the Court held the trial court did not err. Although no written partnership agreement had been produced and the Court recognized the rule that declarations of one partner alone are generally incompetent to prove partnership and that reputation or hearsay cannot establish a partnership, the Court concluded that the testimony of the witnesses other than Kiel, together with documentary evidence, left a firm impression that Kiel and Sabert entered into an equal copartnership. The Court emphasized that the primary inquiry was the intention of the parties as gathered from their language and conduct, citing Giles v. Vette.

Ruling on the Judgment and Remedy

The Court found error seven well taken in part. The Court observed that the trial court awarded Kiel the full sum claimed, apparently on the theory that Sabert had sold property to the Nituan Plantation Company for P40,000 and that Kiel was entitle

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.