G.R. No. 118230 October 16, 1997
ABUNDIA BINGCOY, ISIDRO S. BINGCOY, MAMERTO S. BINGCOY, CORAZON S. DAGOY, DOMINGO DAGOMAS, SEGUNDINO LUMHOD, QUIRICO LUMHOD, OTELIA LUMHOD, VICTOR LUMHOD, JOSE BINGCOY, PELAGIA BINGCOY, FELISA BINGCOY, CESAR BINGCOY, DELFIN SAYRE, JESUS SAYRE, MARIA SAYRE, ANASTACIO SAYRE, FLORENTINO BEATE, and ISABELO LUMHOD, petitioners, vs. THE HONORABLE COURT OF APPEALS, VICTORIANO BINGCOY, and AGUSTIN BINGCOY, respondents.

FACTS

On May 31, 1952, private respondents Victoriano and Agustin Bingcoy filed a Complaint for Recovery of Property in the Court of First Instance (now Regional Trial Court) of Negros Oriental. They alleged that in July 1948, petitioners attacked them at their residence, shot their animals, threatened their lives, and forced them to flee. Petitioners then usurped and occupied their house and lands, refusing to vacate despite demands. The complaint detailed three causes of action: 1) Private respondents claimed ownership by inheritance of three parcels of land from their father Juan Cumayao and one parcel from their brother Prudencio Bingcoy; 2) Victoriano Bingcoy claimed ownership of three parcels acquired by donation and purchase; and 3) Agustin Bingcoy claimed ownership of one parcel acquired by purchase. Petitioners countered that Juan Cumayao died single and without children, as shown by his Death Certificate, and that the properties originally belonged to spouses Marcos Cumayao and Francisca Morales, the parents of Juan and grandparents of petitioners, to whom they succeeded as heirs. During trial, private respondents presented testimonial and documentary evidence, including a certificate from the Local Civil Registrar (Exhibit “A”) and a marriage certificate (Exhibit “B”), to prove the marriage of Juan Cumayao and Claudia Bingcoy and the filiation of the private respondents. The trial court rendered a decision in favor of private respondents, declaring them the lawful owners and ordering petitioners to vacate and pay damages. The Court of Appeals affirmed this decision. Petitioners appealed to the Supreme Court, arguing that the documentary evidence (Exhibits “A” and “B”) were improperly admitted as they were not formally offered in evidence and were later withdrawn.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s decision which relied on documentary evidence (Exhibits “A” and “B”) that were not formally offered in evidence and were subsequently withdrawn.

RULING

The Supreme Court dismissed the petition for lack of merit. The Court held that the technical withdrawal of the documents (Exhibits “A” and “B”) upon the petitioners’ insistence did not nullify the testimonial evidence that attested to their contents. The witness, Victoriano Bingcoy, had fully testified on the documents, which were marked and identified during the hearings. The Court emphasized that courts of law should not sacrifice substantial justice for legalism. The withdrawal was a mere technicality that did not erase the truths established by the documents. The trial court and the Court of Appeals correctly considered the evidence in rendering their decisions. The Supreme Court affirmed the findings of the lower courts.