Craig v. Leuterio
REITERATIONFacts
The Antecedents: Plaintiff, as the judicial administrator of the estate of the deceased Ramon Valencia, filed an action against the defendant to recover possession of real and personal property allegedly belonging to the estate. The core of the dispute revolved around a deed of land dated November 25, 1893, purportedly signed by the defendant, conveying the land to Ramon Valencia. Procedural History: The Court of First Instance of Mindoro rendered judgment in favor of the plaintiff, awarding the real estate described in the complaint. The defendant appealed this decision. The Petition: The defendant appealed the judgment, primarily questioning the authenticity of the deed of conveyance and the admissibility of the document and its inscription in the registry of property.
Issue(s)
Whether the deed of conveyance dated November 25, 1893, is authentic. Whether the deed of conveyance, not being a public document, is valid between the parties. Whether the inscription of the deed in the registry of property in 1906 was valid and admissible in evidence. Whether the plaintiff sufficiently proved his appointment as judicial administrator of the estate of Ramon Valencia.
Ruling
The Supreme Court reversed the judgment of the lower court and remanded the case for a new trial. The Court found that while the evidence regarding the authenticity of the deed preponderated in favor of the plaintiff, the plaintiff failed to prove his appointment as judicial administrator, which was denied by the defendant. The Court granted a new trial to allow the plaintiff to remedy this defect in evidence.
Ratio Decidendi
On the authenticity of the deed of conveyance: The Court found that the evidence, though conflicting, clearly preponderated in favor of the plaintiff. While the widow did not witness the defendant sign the document, she testified that the defendant brought it to their house and delivered it to her husband. Other evidence also tended to prove the defendant's signature on the conveyance. On the validity of the deed as a private document: The Court reiterated its repeated holdings that a deed of conveyance is valid between the parties thereto, even if its requirements under Article 1280 of the Civil Code (not being executed before a notary public) are not complied with. This principle was applied in cases such as Thunga Chui vs. Que Bentec, Guillermo vs. Matienzo et al., and Couto Soriano vs. Cortes. On the admissibility of the inscribed document: The Court held that Article 389 of the Mortgage Law is not applicable to cases arising between the parties to the instrument. The defendant, being a party to the conveyance, is not considered a third person within the meaning of the said article. Therefore, the inscription of the document in the registry of property did not render it inadmissible in evidence against him, consistent with rulings in Fabian vs. Smith, Bell and Co., Guillermo vs. Matienzo et al., Bonacan vs. Smith, Bell and Co., and Roxas vs. Aguirre. On the proof of appointment as judicial administrator: The Court found the plaintiff's claim of being the duly appointed judicial administrator to be unsubstantiated. The defendant's answer denied this allegation, making it incumbent upon the plaintiff to present evidence of his appointment. The Court rejected the appellee's argument that the defendant waived this proof by failing to demur, as a demurrer would have admitted the allegation, not questioned the proof thereof. This assignment of error was found to be well-founded, necessitating the reversal of the judgment.
Main Doctrine
A deed of conveyance, though not executed before a notary public and thus not a public document, is valid between the parties thereto. Furthermore, the inscription of such a document in the registry of property does not render it inadmissible in evidence against a party to the instrument, as such a party is not considered a third person within the meaning of Article 389 of the Mortgage Law. However, the plaintiff must prove their appointment as judicial administrator.