G.R. No. 2021

FACTS:
Plaintiff Aniceto Lorenzo filed an action claiming that defendant Jose Navarro was in possession of two fisheries as his tenant under a lease contract executed in 1894 between Navarro and Aniceto’s father, Cornelio Lorenzo. Navarro denied this, asserting that his possession was by virtue of a sale. He presented a document showing that he paid the rent arrears of Cornelio Lorenzo to the parish priest (administrator of the estate) and paid Cornelio for his improvements, thereby acquiring all of Cornelio’s interests in the fisheries. The trial court rejected this document for lack of identification but granted judgment in favor of Navarro.

ISSUE:
Whether the trial court erred in ruling in favor of the defendant, Jose Navarro, based on the evidence presented.

RULING:
No. The Supreme Court affirmed the trial court’s judgment. The Court held that:
1. On the Question of Fact: The evidence strongly preponderated in favor of Navarro’s claim of a sale, not a lease. The document he presented, coupled with the testimonies of both parties, sufficiently identified the fisheries in question and proved that Cornelio Lorenzo had transferred his interests to Navarro.
2. On the Pleadings and Evidence: Navarro’s general denial in his answer was sufficient to allow him to prove facts showing the contract was one of sale, as this directly negated the plaintiff’s allegation of a lease. A special defense was not required.
The judgment was affirmed, with costs against the appellant.