Antillon v. Barcelon
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the possession and ownership of a specific parcel of land. The plaintiff, Jose Antillon, claims ownership and alleges that the defendant, Leoncio Barcelon, as administrator of the estate of Antonio Bueno, is unlawfully interfering with his possession. 2. Procedural History: The action was initiated in the Court of First Instance of Laguna on August 28, 1913. The plaintiff opposed the defendant's petition to register the land in the Court of Land Registration (Cause No. 8350), asserting his own ownership. The Court of Land Registration ruled in favor of the plaintiff, denying the defendant's registration. Despite this decision, the defendant continued to interfere with the plaintiff's possession. The Court of First Instance subsequently rendered a judgment in favor of the plaintiff, declaring him the owner and awarding damages. The defendant appealed this decision. 3. The Petition: The defendant appealed the judgment of the Court of First Instance to the Supreme Court, raising several assignments of error. The primary contention, addressed in the first assignment of error, challenged the admissibility of Exhibits E and F (documents evidencing the plaintiff's title) on the grounds of improper identification and unproven execution and delivery. The appellant argued these private documents required further proof beyond their acknowledgment before a notary public. The second assignment of error concerned the admissibility of Exhibit G-1, the record from the Court of Land Registration, with the implied objection being lack of identification by the custodian.
Issue(s)
Whether Exhibits E and F, documents acknowledged before a notary public, were admissible in evidence without further proof of their execution and delivery. Whether the lower court erred in admitting Exhibit G (G-1), the record of the Court of Land Registration.
Ruling
The Supreme Court affirmed the decision of the lower court, ruling that the plaintiff is the owner and entitled to the peaceable and quiet possession of the land in question.
Ratio Decidendi
On the admissibility of Exhibits E and F: The Court held that a document duly acknowledged before a notary public under his hand and seal, with his certificate thereto attached, is admissible in evidence without further proof of its due execution and delivery. The Court reasoned that notaries public are officers whose official acts receive credence not only in their own country but in all others. The law reposes confidence in public officers, presuming they discharge their trusts with accuracy and fidelity. Section 331 of Act No. 190 explicitly provides that instruments conveying or affecting real property, if acknowledged or proved and certified as provided by law, may be read in evidence without further proof. This is one of the purposes of requiring acknowledgment before a notary public, to give such documents the force of evidence without additional proof, unless the verity of the acknowledgment and certificate is questioned. On the admissibility of Exhibit G (G-1): The Court found no error in admitting Exhibit G (G-1), the record of the Court of Land Registration. The Court explained that under Section 18 of Act No. 2347, clerks of courts are ex officio deputies of the Chief of the General Land Registration Office and are authorized to identify records made up in the Courts of First Instance relating to land registration. As the custodian of such records, the clerk of the Court of First Instance was fully authorized to identify the record in question.
Main Doctrine
A document duly acknowledged before a notary public under his hand and seal, with his certificate thereto attached, is admissible in evidence without further proof of its due execution and delivery, unless and until some question is raised as to the verity of said acknowledgment and certificate.