G.R. No. L-6664, March 29, 1912
PEDRO GERALDO, plaintiff-appellee, vs. MATEO ARPON, defendant-appellant.

FACTS

Pedro Geraldo filed an action to recover ownership and possession of a parcel of rice land in Leyte, as well as its products since 1904. To establish ownership, Geraldo presented a certified copy of a possessory information obtained in 1897 and duly registered in 1898, along with testimonial evidence that he had been in possession of the land for over twenty years prior to 1904. Mateo Arpon, the defendant, claimed ownership based on a notarial document dated April 30, 1910, purporting to evidence a sale to him in 1890 by the Cirera brothers. Arpon also presented witnesses testifying that he had been in possession of part of the land since 1890, and that another portion was held by Epifanio Blancaflor. The trial court ruled in favor of Geraldo, declaring him the owner of the portion possessed by Arpon and awarding him P175 as the value of the land’s products. Arpon appealed.

ISSUE

1. Whether the trial court erred in admitting the certified copy of the possessory information as evidence.
2. Whether Geraldo is the rightful owner of the land in question.
3. Whether the award for the products of the land since 1904 is proper.

RULING

1. No, the trial court did not err in admitting the certified copy of the possessory information. The document was a certified copy from the property registry, made by the register of deeds. Under Section 284 of the Code of Civil Procedure, an exception to the best evidence rule allows for the presentation of a copy when the original is a public record in the custody of a public official. Moreover, Arpon’s objection to its admissibility was raised for the first time on appeal and was thus untimely.

2. Yes, Geraldo is the rightful owner of the land. The possessory information, coupled with his testimonial evidence, sufficiently established his ownership. In contrast, Arpon’s claim based on the notarial document was unreliable. The document was executed on April 30, 1910just ten days before the lawsuit was filedand Arpon’s testimony that he received it in 1890 was contradicted by the document’s face. The Court found that the notarial document was fabricated to defeat Geraldo’s claim, and Arpon failed to present any original private document from 1890 to substantiate his purchase.

3. No, the award for the products of the land was improper. While Geraldo was entitled to recover possession, the evidence regarding the value of the land’s products since 1904 was too indefinite and uncertain. The record did not specify the exact area occupied by Arpon, the share of the crop due to a landlord versus an occupant, or reliable data on annual production and prices. Therefore, the monetary award for the products could not be sustained.

DISPOSITIVE PORTION:
The appealed judgment was MODIFIED by disallowing recovery for the products of the land. As modified, the judgment was AFFIRMED, without costs.