Estabillo v. Estabillo
REITERATIONFacts
The Antecedents: Plaintiffs alleged ownership of a 30-hectare land in Tarlac. They claimed to have authorized the defendant, whom they trusted, to represent them in a cadastral case (No. 4, Tarlac) to file a claim for the eastern portion, lot No. 1359 (117,692 sq. meters). However, the defendant allegedly betrayed their trust by filing a claim in his own name and obtaining a decree of registration in September 1917. Plaintiffs discovered this fraud in 1919, after which the defendant took possession of the lot. Procedural History: The plaintiffs filed a complaint seeking a declaration of ownership prior to 1917, annulment of the defendant's decree for being illegal and fraudulent, and damages amounting to P23,000. The defendant filed a general denial. The trial court found that the plaintiffs failed to establish their title and rendered judgment in favor of the defendant, absolving him and ordering the plaintiffs to pay costs. The Appeal: The plaintiffs appealed the trial court's decision, raising seven assignments of error. Assignments 1, 2, 4, 5, 6, and 7 pertained to questions of fact, which the appellate court found to be fully sustained by the evidence. The third assignment of error challenged the admission of the defendant's Exhibit 1, an affidavit by Simon Estabillo dated May 1908. In this affidavit, Simon, son and sole heir of the original owner Santiago Estabillo, stated he knew his father sold the land to the defendant and relinquished all his rights. The affidavit was sworn to before a notary public and signed by three witnesses.
Issue(s)
Whether the trial court erred in admitting Defendant's Exhibit 1, an affidavit by Simon Estabillo, as evidence. Whether the plaintiffs established their title to the land in question.
Ruling
The judgment appealed from is affirmed, with costs against the appellants. The Supreme Court upheld the trial court's decision, finding that the plaintiffs failed to establish their title and that the admission of Defendant's Exhibit 1 was proper.
Ratio Decidendi
On the admissibility of Defendant's Exhibit 1: The Supreme Court held that the affidavit of Simon Estabillo was admissible as an admission against interest. It was undisputed that Simon's father, Santiago Estabillo, was the original owner, and both parties claimed title through him. Furthermore, Simon was the father of one of the appellants, Fausta Estabillo, and both Santiago and Simon had died before the action was filed. The affidavit, therefore, constituted an admission against interest by a predecessor of an appellant and was an exception to the hearsay rule. It was also admissible to show that the defendant had been in possession of the land under a claim of ownership adverse to the claims of Santiago Estabillo's descendants. The Court noted that the fact that the witness testifying to the affidavit's authenticity was not present when it was written and signed by other witnesses might lessen its probatory value but did not render it inadmissible. On the plaintiffs' failure to establish title: The Supreme Court found that the trial court's findings of fact were fully sustained by the evidence. The appellants' assignments of error relating to questions of fact were deemed without merit. Consequently, the plaintiffs failed to prove their ownership of the land, leading to the affirmation of the judgment in favor of the defendant.
Main Doctrine
An affidavit by a predecessor in interest, acknowledging a sale and relinquishing rights, is admissible as an admission against interest against his heirs, and also to show the adverse claim of the defendant, even if the affiant is unavailable and the witness to its execution has some testimonial inconsistencies regarding its signing. The document's probatory value may be affected but not its admissibility.