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    Similar Acts As Evidence

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    Tootsie Guzma
    1) The case discusses the doctrine of collateral facts as evidence and the exception to the rule of res inter alios acta. 2) It involves a dispute over land titles between the Cruz family who claim co-ownership and the Malolos family who purchased the land in a sheriff's sale due to unpaid debts of Nerissa Tamayo. 3) The court ruled that evidence of similar transactions of other parcels between the Cruz family falls under the exception to the res inter alios acta rule, as it is relevant to show that all the parcels covered under the DPP and MOA were treated as absolute rather than co-owned property.

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    Similar Acts As Evidence

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    Tootsie Guzma
    268 views3 pages
    1) The case discusses the doctrine of collateral facts as evidence and the exception to the rule of res inter alios acta. 2) It involves a dispute over land titles between the Cruz family who claim co-ownership and the Malolos family who purchased the land in a sheriff's sale due to unpaid debts of Nerissa Tamayo. 3) The court ruled that evidence of similar transactions of other parcels between the Cruz family falls under the exception to the res inter alios acta rule, as it is relevant to show that all the parcels covered under the DPP and MOA were treated as absolute rather than co-owned property.

    Original Title

    Cruz-v.-CA

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    1) The case discusses the doctrine of collateral facts as evidence and the exception to the rule of res inter alios acta. 2) It involves a dispute over land titles between the Cruz family who claim co-ownership and the Malolos family who purchased the land in a sheriff's sale due to unpaid debts of Nerissa Tamayo. 3) The court ruled that evidence of similar transactions of other parcels between the Cruz family falls under the exception to the res inter alios acta rule, as it is relevant to show that all the parcels covered under the DPP and MOA were treated as absolute rather than co-owned property.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    268 views3 pages

    Similar Acts As Evidence

    Uploaded by

    Tootsie Guzma
    1) The case discusses the doctrine of collateral facts as evidence and the exception to the rule of res inter alios acta. 2) It involves a dispute over land titles between the Cruz family who claim co-ownership and the Malolos family who purchased the land in a sheriff's sale due to unpaid debts of Nerissa Tamayo. 3) The court ruled that evidence of similar transactions of other parcels between the Cruz family falls under the exception to the res inter alios acta rule, as it is relevant to show that all the parcels covered under the DPP and MOA were treated as absolute rather than co-owned property.

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    © All Rights Reserved
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    Download as docx, pdf, or txt
    of 3

    SIMILAR ACTS AS EVIDENCE

    Adoracion Cruz, et al. v. CA, et al.


    G.R. No. 126713, July 27, 1998
    Panganiban, J.:

    DOCTRINE:
    Collateral facts may be admitted in evidence when a rational
    similarity exists between the conditions giving rise to the fact
    offered and the circumstances surrounding the issue or fact to be
    proved.

    FACTS:
    Adoracion Cruz and her children executed a notarized deed
    of partial partition (DPP) by virtue of which each one of them was
    given a share of several parcels of registered lands all situated in
    Taytay, Rizal. The following day, they executed a Memorandum of
    Agreement (MOA) which caused the consolidation of the
    properties/lands. Titles were issued in their names, some of
    which are registered in the name of Nerissa Tamayo. Meanwhile
    Spouses Malolos filed an action for the collection for a sum of
    money. The trial court in the said case condemned the spouses
    Tamayo which, as a result, the sheriff of the court levied upon the
    subject land and were subsequently sold to the highest bidders,
    the spouses Malolos. Nerissa Tamayo failed to exercise her right
    of redemption within the statutory period and so the final deed of
    sale was executed by the sheriff in favor of the spouses Malolos.
    Due to Tamayo’s failure to heed the court’s order to surrender
    the subject titles, Malolos asked the court to declare said titles as
    null and void. At this point, petitioners Adoracion Cruz, et al.,
    intervened contending that they are co-owners of the subject
    lands. The trial court ruled in favor of the spouses Malolos and
    subsequently affirmed by the CA. It was contended by the
    petitioners that the MOA revoked and supersede the DPP and
    thus they are co-owners of the subject lands and further invoke
    the res inter alios act rule against the agreement of Tamayo and
    the Spouses Malolos.

    ISSUE:
    Whether or not collateral facts may be received as evidence
    in the case at bar

    RULING:
    Yes, collateral facts may be received as evidence in the case
    at bar.
    Res inter alios acta, as a general rule, prohibits the
    admission of evidence that tends to show that what a person has
    done at one time is probative of the contention that he has done
    a similar as act at another time. Evidence of similar acts or
    occurrences compels the defendant to meet allegations that are
    not mentioned in the complaint, confuses him in his defense,
    raises a variety of irrelevant issues, and diverts the attention of
    the court from the issues immediately before it. Hence, this
    evidentiary rule guards against the practical inconvenience of
    trying collateral issues and protracting the trial and prevents
    surprise or other mischief prejudicial to litigants.
    The rule, however, is not without exception. While
    inadmissible in general, collateral facts may be received as
    evidence under exceptional circumstances, as when there is a
    rational similarity or resemblance between the conditions giving
    rise to the fact offered and the circumstances surrounding the
    issue or fact to be proved. Evidence of similar acts may
    frequently become relevant, especially in actions based on fraud
    and deceit, because it sheds light on the state of mind or
    knowledge of a persons; it provides insight into such persons
    motive or intent; it uncovers a scheme, design or plan; or it
    reveals a mistake.
    In this case, petitioners argue that transactions relating to
    the other parcels of land they entered into, in the concept of
    absolute owners, are inadmissible as evidence to show that the
    parcels in issue are not co-owned. The court is not persuaded.
    Evidence of such transactions falls under the exception to the rule
    on the res inter alios acta. Such evidence is admissible because it
    is relevant to an issue in the case and corroborative of evidence
    already received. The relevancy of such transactions is readily
    apparent. The nature of ownership of said property should be the
    same as that of the lots on question since they are all subject to
    the MOA. If the parcels of land were held and disposed by
    petitioners in fee simple, in the concept of absolute owners, then
    the lots in question should similarly be treated as absolutely
    owned in fee simple by the Tamayo spouses. Unmistakably, the
    evidence in dispute manifests petitioners common purpose and
    design to treat all the parcels of land covered by the DPP as
    absolutely owned and not subject to co-ownership.

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