G.R. No. 127745; April 22, 2003
FELICITO G. SANSON, CELEDONIA SANSON-SAQUIN, ANGELES A. MONTINOLA, EDUARDO A. MONTINOLA, JR., petitioners-appellants, vs. HONORABLE COURT OF APPEALS, FOURTH DIVISION and MELECIA T. SY, as Administratrix of the Intestate Estate of the Late Juan Bon Fing Sy, respondents-appellees.

FACTS

Petitioners filed separate claims against the intestate estate of Juan Bon Fing Sy based on unpaid checks issued by the deceased before his death. During the hearing, the claimants presented testimonial and documentary evidence. Felicito Sanson testified to support his sister Celedonia’s claim, Celedonia testified for her brother’s claim, and Jade Montinola (wife of claimant Eduardo Jr. and daughter-in-law of claimant Angeles) testified for the Montinola claims. The administratrix, Melecia Sy, objected to this testimony under the “Dead Man’s Statute” (Section 23, Rule 130), which disqualifies a party or interested witness from testifying on matters occurring before the death of the deceased when the testimony is against the latter’s estate. The trial court overruled the objections, admitted the evidence, and ordered payment of the claims. The Court of Appeals reversed, applying the Dead Man’s Statute to disqualify the witnesses and dismissing the claims for lack of competent evidence.

ISSUE

Whether the testimonies of the witnesses are inadmissible under the Dead Man’s Statute, thereby rendering the claims against the estate unsubstantiated.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the trial court’s order. The legal logic centered on the proper application of the Dead Man’s Statute. The Court held that the statute’s disqualification applies only to a party or the assignor of a party testifying against the executor or administrator regarding a claim against the estate. Here, the witnesses were not testifying in support of their own claims against the estate. Sanson testified for his sister’s claim, Celedonia testified for her brother’s claim, and Jade Montinola testified for her husband’s and mother-in-law’s claims. They were not parties to those specific claims. Therefore, they were not disqualified from testifying as to transactions with the deceased. Their testimonies, which identified the checks issued by the deceased and established their subsequent dishonor due to account closure, were competent and admissible. Coupled with the administratrix’s decision to dispense with presenting contrary evidence, the claimants successfully discharged their burden of proof. The checks, as commercial documents, carried prima facie evidence of consideration, and the testimonies validly complemented them.