Title
Lagmay vs. Quinit
Case
G.R. No. L-10902
Decision Date
Jan 31, 1958
Plaintiffs claimed land ownership via a 1943 Ilocano writing, but rights were waived in a prior settlement; SC upheld inadmissibility of untranslated document and mootness of claims.

Case Summary (G.R. No. L-10902)

Background of the Case

The property in dispute is detailed in Original Certificate of Title No. 25620. Following the expiration of the redemption period without any repurchase by Basto, Florida Lagmay and Esteban Madruno assert that they purchased the same land from Emerenciana Quinit in 1943 for P450. Their claim relies on a document in the Ilocano dialect, which they interpret as evidence of a valid transaction granting them ownership rights to the property.

Lower Court Proceedings

The lower court ruled in favor of the defendants, finding that the Ilocano writing on the document represented a mere subrogation of rights from Basto to the plaintiffs and not an outright sale. The court also noted that prior to the present case, Floserfida Basto, a relative of the original owner, initiated a separate action claiming rights to the same land, which was settled amicably, resulting in financial compensation for both Basto and the plaintiffs.

Legal Findings

The trial court ultimately dismissed the plaintiffs’ complaint, determining that they had no remaining rights to the property based on the earlier settlement agreement. The appellate court, in reviewing the case, found that the plaintiffs’ appeal was limited to a legal question regarding the proper interpretation of the Ilocano writing and did not contest the substantive findings of the trial court regarding prior transactions.

Admissibility of Evidence

A significant point was the admissibility of the Ilocano dialect writing. The appellate court noted that a translation was required for the document to be considered valid evidence but was never provided by the plaintiffs. This omission rendered the writing inadmissible according to Section 57 of Rule 123 of the Rules of Court, ultimat

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