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FELICITO G. SANSON v. CA

FACTS:

The petitioners in this case filed a petition for the settlement of the estate of Juan Bon Fing Sy. Among the petitioners were Felicito G. Sanson, claiming a debt of P603,000.00, and Celedonia Sanson-Saquin, claiming a debt of P360,000.00. Later on, Eduardo Montinola, Jr. and his mother Angeles Montinola also filed separate claims against the estate, alleging debts of P50,000.00 and P150,000.00, respectively. The court appointed Melecia T. Sy, the surviving spouse of the deceased, as the administratrix of his estate. During the hearing of the claims, Sanson, Celedonia, and Jade Montinola testified on the transactions that gave rise to their claims. The administratrix objected to their testimony, invoking the Dead Man's Statute which disqualifies parties or assignors of parties to a case against a deceased person from testifying about any matter of fact occurring before the death of the deceased person. The administratrix also denied the existence of the claims and objected to the admission of the checks and check return slips offered as evidence by the claimants. After the claimants rested their case, the administratrix filed manifestations informing the court that she was dispensing with the presentation of evidence against their claims. The trial court, finding that the Dead Man's Statute does not apply to the witnesses who testified, ordered the administratrix to pay the claimants out of the assets of the estate. The Court of Appeals, however, set aside the trial court's order and dismissed the claims. The claimants filed a motion for reconsideration, which was denied, leading to the filing of the present petition.

ISSUES:

  1. Whether the testimony of Jade Montinola is sufficient to prove the claims of claimants Angeles A. Montinola and Eduardo A. Montinola, Jr.

  2. Whether claimant Felicito G. Sanson is disqualified to testify on the claim of Celedonia Sanson-Saquini and vice versa.

  3. Whether or not Sanson and Saquin are disqualified from testifying for each other as co-parties to the same case.

  4. Whether or not the claims of Sanson and Celedonia against the estate arose from separate transactions.

  5. Whether or not the Dead Man's Statute applies to the claims of Sanson and Celedonia.

  6. Whether or not the testimonies of Sanson and Celedonia are sufficient to establish the authenticity of the deceased's signature.

RULING:

  1. The Court ruled that Jade Montinola's testimony is sufficient to prove the claims of Angeles A. Montinola and Eduardo A. Montinola, Jr. The genuineness of the deceased's signature on the checks issued to the Montinolas was clearly established through Jade's testimony. The testimony showed that Jade was present when the deceased signed the checks, thereby proving the authenticity of his signature. In this regard, the Court applied the presumption of consideration under the Negotiable Instruments Law, which deems every negotiable instrument to have been issued for valuable consideration. Since the administratrix failed to rebut or contradict this presumption, it became conclusive in favor of the Montinolas' claims.

  2. The Court held that Felicito G. Sanson is not disqualified to testify on the claim of Celedonia Sanson-Saquini and vice versa. The Dead Man's Statute renders incompetent parties to a case, their assignors, and persons in whose behalf the case is prosecuted from testifying. However, Jade is not a party to the case, an assignor, or a person in whose behalf the case is being prosecuted. She testified as a witness to the transaction. The Court also noted that family members or relatives of the parties commonly testify as witnesses in similar transactions. The Court further emphasized that the Dead Man's Statute is exclusive and should not be construed to disqualify persons not mentioned therein. Hence, Jade's testimony and the testimonies of Sanson and Celedonia are admissible and not covered by the Dead Man's Statute.

  3. Sanson and Saquin are not disqualified from testifying for each other as co-parties to the same case. They are considered third parties with respect to each other's claim, and one is not disqualified from testifying on the other's transaction.

  4. The claims of Sanson and Celedonia against the estate arose from separate transactions. They are not disqualified to testify for each other.

  5. The Dead Man's Statute does not apply to the claims of Sanson and Celedonia because it only prohibits the admission of testimonial evidence upon a claim that arose before the death of the deceased. Since their claims are supported by checks as documentary evidence, they can be prosecuted based on these checks.

  6. Although the testimonies of Sanson and Celedonia regarding the authenticity of the deceased's signature do not meet the standard required by the rules of evidence, the administratrix failed to controvert their testimony. Therefore, from a comparison of the deceased's signature on the checks issued to different claimants, it appears that they were affixed by one and the same hand, supporting the authenticity of the signature.

PRINCIPLES:

  • The genuineness of a signature can be proven through the testimony of a witness who was present when the signature was made.

  • The presumption of consideration under the Negotiable Instruments Law applies to checks, deeming them to have been issued for valuable consideration.

  • The Dead Man's Statute renders incompetent parties to a case, their assignors, and persons in whose behalf the case is prosecuted from testifying. It does not extend its scope to disqualify witnesses who are not included in the specified categories.

  • The Dead Man's Statute disqualifies parties or assignors to a case from testifying, regardless of whether it is for their own behalf or on behalf of others.

  • The Dead Man's Statute applies to claims that arose before the death of the deceased.

  • The incompetency under the Dead Man's Statute is limited to giving testimony and does not apply to the admission of documentary evidence.

  • The authenticity of a signature can be established through testimonial evidence by witnesses who believe it to be the handwriting of the person or who have seen writing purporting to be his and have thus acquired knowledge of his handwriting.