Tuesday, September 20, 2016

Comilang vs Barcena GR No. 146853. February 13, 2016

Facts:
                Respondents, together with their mother Dominga, filed a complaint for annulment of document with damages against petitioner Salvador Comilang. The complaint alleges that respondents are the owner of a parcel of land and house built thereon; respondents acquired the subject property through their earnings while working abroad; and the subject property was declared for taxation purposes in the Dominga’s name as administrator.
                Petitioner caused the execution of a Deed of Donation over said property by taking advantage of Dominga’s blindness, old age and physical infirmity.
                RTC rendered decision in favor of respondents and deed of donation null and void.
                CA sustained the conclusion of the RTC that the donation is void.
                Petitioner assails the CAs application of the principle of implied trust to nullify the Deed of Donation executed in his favor. He asserts that the existence of an implied trust between respondents and Dominga in relation to the subject property was never treated by the RTC nor was it brought in issue on appeal before the CA. Petitioner further argues that Margaritas statement on the witness stand that Dominga told her that the respondents sent her money to buy the subject property, should not have been given weight or credence by the RTC and the CA because it is hearsay and has no probative value.

Issue:
                Whether or not Margarita’s testimony is hearsay.
               
Ruling:
                No.
Anent Margaritas testimony that Dominga told her that the respondents sent her (Dominga) money to buy the subject property, it cannot be categorized as hearsay evidence. Margaritas testimony was not presented to prove the truth thereof, but only to establish the fact that Dominga narrated to Margarita the source of the funds used in the purchase of the subject property. What was sought to be admitted in evidence, and what was actually admitted in evidence, was the fact that the statement was made by Dominga to Margarita, not necessarily that the matters stated by her were true. The said utterance is in the nature of an independently relevant statement which may be admitted in evidence as such, but not necessarily to prove the truth thereof.

Thus, while it is true that the testimony of a witness regarding a statement made by another person, if intended to establish the truth of the fact asserted in the statement, is clearly hearsay evidence, it is otherwise if the purpose of placing the statement in the record is merely to establish the fact that the statement was made or the tenor of such statement.  Regardless of the truth or falsity of a statement, when the fact that it has been made is relevant, the hearsay rule does not apply and the statement may be shown. As a matter of fact, evidence as to the making of the statement is not secondary but primary, for the statement itself may constitute a fact in issue, or be circumstantially relevant as to the existence of such a fact.  For this reason, the statement attributed to Dominga regarding the source of the funds used to purchase the subject property related to the court by Margarita is admissible if only to establish the fact that such statement was made and the tenor thereof.

Besides, the testimony of Margarita is not the main basis for the RTCs decision. In fact, her testimony is not indispensable. It merely serves to corroborate the testimonies of the respondents on the source of the funds used in purchasing the subject property. The testimonies of all three witnesses for the plaintiffs were found to be convincing and credible by the RTC. This Court will not alter the findings of the RTC on the credibility of witnesses, principally because trial courts have vastly superior advantages in ascertaining the truth and in detecting falsehood as they have the opportunity to observe the manner and demeanor of witnesses while testifying.


                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

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