G.R. No. L-3772
LAURENTE BALDOVINO, plaintiff-appellant, vs. PEDRO AMENOS, ET AL., defendants-appellees.
January 10, 1908

FACTS:
Laurente Baldovino, as administrator of the estate of Agustin Lukban de San Miguel (who died in 1881), filed an action in the Court of First Instance of Ambos Camarines to recover the possession of the 80-hectare Pangpang estate, claiming it belonged to Agustin’s heirs. One of the heirs, Vicente Lukban, had, in 1894, obtained a possessory information for the Pangpang estate and 34 other parcels, claiming ownership by inheritance from his father Agustin and possession since 1881. This possessory information was recorded on September 7, 1894.

In 1896, the Pangpang estate, then in Vicente Lukban’s possession, was attached as his property in a separate judicial proceeding against him. It was subsequently sold at a judicial sale to Ildefonso Moreno on April 22, 1896. A deed was executed to Moreno by the court on December 24, 1896, and recorded on January 2, 1897. On January 4, 1897, Ildefonso Moreno sold the Pangpang estate to the defendant Pedro Amenos, and this deed was recorded on January 21, 1897. Prior to this, on April 7, 1896, Vicente Lukban had entered into an administration contract with Amenos, where he declared himself the sole owner of the property and delivered its possession to Amenos.

The plaintiff presented Agustin Lukban’s will (1881), which did not specifically describe Pangpang, and devised properties to children and strangers. No evidence of estate partition was offered. Vicente Lukban, testifying for the plaintiff, stated that the properties belonged to all of Agustin’s children, registered in his name by agreement, and that the haciendas were “undivided among the heirs.” This testimony conflicted with his earlier written declarations of sole ownership. The appellant also argued that Amenos, being an administrator of the property, was prohibited from purchasing it under Article 1459 of the Civil Code.

ISSUE:
1. Did the plaintiff present sufficient evidence to overcome the prima facie case of ownership in favor of Vicente Lukban and consequently, Pedro Amenos?
2. Was Pedro Amenos’ acquisition of the property invalid under Article 1459 of the Civil Code due to his role as administrator?

RULING:
1. No. The Court ruled that the plaintiff failed to overcome the strong prima facie evidence of ownership established by Vicente Lukban’s recorded possessory information, his long possession, his explicit declarations of sole ownership in prior judicial proceedings and contracts, and the subsequent judicial sale and transfers. Vicente Lukban’s contradictory testimony at trial, claiming the property belonged to all heirs despite his previous written declarations of sole ownership, was deemed insufficient to rebut the established evidence.
2. No. The prohibition in Article 1459 of the Civil Code, which disallows agents from purchasing property they are entrusted to administer, did not apply. Pedro Amenos did not purchase the property directly from his principal, Vicente Lukban. The actual purchaser at the judicial sale was Ildefonso Moreno. For Article 1459 to apply to Amenos, there would need to be proof of an agreement between Amenos and Moreno for Moreno to buy the property for Amenos’ benefit (as a persona intermedia). No such agreement was established by the evidence on record.

The Court affirmed the judgment of the lower court.