Bautista Vs.

Abarece
51 O.G. 806 (1995)

Facts: Nicolas Anasco is the owner of a lot who sold the same to Valentin Justiniani, who later on sold
the said lot to Claudio Justiniane. Claudio , later on, executed a public instrument whereby he sold the
property to Apolonio Aparece, in whose name it was assessed while Aparece was in possession was in
possession, of the land, Hermogenes Bautista illegally entered a part of the lot and took possession
thereof. Aparece filed a complaint with the guerilla forces. After being called for hearing and after
inspection was made by the guerilla officer, Bautista executed a public instrument wherein he
permitted to return the land to Aparece in good will, and recognize Aparece ‘s lawful ownership over
the land. Thus, possession of the land was returned to Aparece.

Bautista filed a complaint with the court of First Instance, which decided in Aparece’s favor as
well. On appeal, Bautista raised as defense the error of the trial court in admitting the public instrument
which he executed as evidence. He argued that the documents was executed under duress, violence or
intimidation, and that the guerilla officer before whom , it was executed, had no jurisdiction over the
matter.

Issue:

1.Whether or not the trial court in admitting as evidence a public instrument executed before an
officer who had no jurisdiction over the matter.

Ruling of the Supreme Court:

No. the test for admissibility or inadmissibility of a certain document is whether or not it is relevant,
material, or competent. The public instrument is not only relevant, but it is also material and competent
to the issue of ownership between the litigants. Relevant evidence is one that has any value in reason as
tending to prove any matter probable in an action, and evidence is said to be material when it is directed
to prove a fact in issue as determine by the rules of substantive law and pleadings, while competent
evidence is one that is not excluded by law in a particular case.

With these criteria in mind, the mere fact that the public document was executed before the
guerilla officer does not make the same a irrelevant, immaterial or incompetent to the main issue raised
in the pleadings, the public document, considered together with other evidence documentary and oral,
satisfies the court that the portions of land in question really belong to defendant Aparece.