HEIRS OF BAGAYGAY V.
HEIRS OF PACIENTE
G.R. No. 212126, August
4, 2021
SECOND DIVISION, HERNANDO
J.
Evidence; Original Document; Secondary Evidence; Land Titles and Deeds; Public Land Act; Laches
PRINCIPLE: Documentary evidence prevails over
testimonial evidence. The doctrine of Secondary Evidence of a Lost Document
allows parties to present substitute evidence when the original document is
unavailable.
The case involves a dispute over the ownership of a parcel of land initially granted to Anastacio Paciente, Sr. under a homestead patent. Subsequently, Anastacio allegedly sold the land to his brother-in-law, Eliseo Bagaygay, who then subdivided it and obtained new titles.
Upon the deaths of Anastacio and Eliseo, their respective heirs entered into a legal battle over the land's ownership and possession. The heirs of Anastacio sought to nullify the Deed of Sale and the titles issued to Eliseo, claiming it was executed within the five-year prohibition period under the Public Land Act. On the other hand, the petitioners, heirs of Eliseo, claimed that the sale was valid, that the sale indeed happened in 1958, beyond the five-year prohibition period. They also presented the Marriage Contract of respondent Meregildo to prove that his wedding, for which the money from the sale was supposedly used, took place on June 8, 1958.
The trial court ruled in favor of
Eliseo's heirs, but the Court of Appeals reversed it. The CA gave more weight
to documentary evidence showing the Deed of Sale was executed within the
prohibition period, declaring it void ab initio.
Whether the Deed of Sale executed by
Anastacio in favor of Eliseo is valid.
NO. The Public Land Act's provisions played a significant role in determining the validity of the Deed of Sale. The Act prohibits certain land transactions within a specified period, and compliance with its provisions was crucial in validating the sale.
The Supreme Court ruled in favor of the heirs of Anastacio Paciente, Sr., confirming them as the rightful owners entitled to possess the land. The Court relied on the assessment of evidence, including the Deed of Sale and the land titles. As the original Deed of Sale was not available, the Court considered the Primary Entry Book from the Register of Deeds as secondary evidence, which served as prima facie evidence of the Deed of Sale's execution date. The entries in the official record were deemed credible evidence, leading to the finding that the Deed of Sale was executed within the prohibition period. Consequently, the Deed of Sale was deemed void ab initio. As a result, the heirs of Anastacio were declared as the rightful owners entitled to possession of the land.
The concept of laches was raised as a
defense by the heirs of Eliseo Bagaygay but was not upheld by the Court, since
laches does not apply to void ab initio contracts.
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