**Facts:**
1. **Origin of Dispute:**
– Petitioners are the heirs of Jose Ocampo and Juana Llander-Ocampo, who had ten children.
– Upon their parents’ death, petitioners claim that their parents’ property, a residential/commercial land in Nabua, Camarines Sur, became co-owned among the siblings.
– Fidela Ocampo, one of the siblings, allegedly conveyed the property solely to Belen Ocampo-Barrito via a Deed of Donation Inter Vivos.
2. **Initial Legal Actions:**
– Petitioners initially filed a complaint for partition and damages against Fidela Ocampo and Felicidad Ocampo, claiming co-ownership.
– A supplemental complaint was filed, including Belen Ocampo-Barrito and Vicente Barrito, challenging the validity of the Deed of Donation Inter Vivos on grounds of alleged fraud and undue influence.
3. **Defendants’ Arguments:**
– Belen Ocampo-Barrito asserted she obtained the property legitimately through a sequence of ownership transfers traced back to Adolfo Ocampo, then to Felix Ocampo, who sold it to Fidela in 1953.
– Fidela Ocampo confirmed her absolute ownership over the property and the authenticity of the donation to Belen.
4. **RTC Decision (October 30, 1996):**
– The RTC found in favor of Belen Ocampo-Barrito, upholding her and her husband Vicente Barrito as the sole owners of the property.
– Petitioners’ complaints were dismissed for lack of evidence and prescription.
– Petitioners were ordered to pay damages and attorney’s fees.
5. **CA Decision (October 31, 2001):**
– The CA affirmed the RTC decision but deleted the awards for damages and attorney’s fees.
6. **Supreme Court Petition:**
– Petitioners appealed to the Supreme Court under Rule 45 of the Rules of Court.
**Issues:**
1. **Co-ownership Proof:**
– Whether the evidence presented proves co-ownership of the property.
– Whether Fidela’s acknowledgment of co-ownership establishes the petitioners’ claim.
2. **Validity of Deed of Donation Inter Vivos:**
– Whether the Deed of Donation executed in favor of Belen Ocampo-Barrito was entered in bad faith.
3. **Admissibility and Weight of Evidence:**
– Whether the photographs, testimonial evidence, and acknowledgment of co-ownership suffice to establish petitioners’ co-ownership claim.
– Whether the evidence of respondents is consistent and credible.
4. **Chinese Custom Claim:**
– Alleged custom of placing property in the name of the eldest unmarried child and its impact on ownership claims.
**Court’s Decision:**
1. **Co-ownership Proof:**
– The Supreme Court upheld that no substantial evidence of co-ownership was presented by the petitioners.
– The reliance on the Acknowledgement of Co-ownership was insufficient against documentary evidence presented by Belen.
2. **Validity of Deed of Donation Inter Vivos:**
– The deed was found valid. The court noted that there was a legitimate transfer of ownership from Fidela to Belen.
– Petitioners did not provide evidence of fraud, coercion, or undue influence that would invalidate the deed.
3. **Admissibility and Weight of Evidence:**
– The photographs and other proofs presented by petitioners were found inconclusive.
– The testimonies of petitioners’ witnesses were viewed as insufficient against the robust documentary proofs of Belen.
4. **Chinese Custom Claim:**
– The Court dismissed this claim due to lack of substantial evidence to prove the existence and practice of the alleged custom in that area.
**Doctrine:**
1. **Burden of Proof:**
– In a civil case, the burden of proving an allegation lies with the party making the claim, based on a preponderance of evidence.
– The party seeking partition must sufficiently prove their title and nature of their ownership.
2. **Co-ownership:**
– Co-ownership cannot be presumed; it must be proven by cogent evidence.
3. **Validity of Contracts:**
– Donative deeds, like any contract, are binding if they fulfill elements of a valid donation – consent, subject matter, and cause.
**Class Notes:**
1. **Ownership and Transfer of Property:**
– A title certificate and tax declarations are significant pieces of evidence of ownership.
– Evidentiary requirements for proving ownership include tracing the succession of title and presenting substantial proof.
2. **Contracts:**
– Essential requisites for donations and property conveyances must be met to validate such acts.
– Mortgages require an absolute owner to affirm the validity of a contract.
3. **Burden of Proof:**
– The party making a claim must supply preponderant evidence to prevail.
4. **Legal Presumptions:**
– Certificates of Title enjoy a presumption of validity unless proven otherwise.
**Historical Background:**
– The case underscored the importance of judiciary adherence to procedural and substantive legal standards in resolving property disputes.
– It highlighted the evidentiary burdens in co-ownership claims and emphasized the supremacy of documentary evidence over general allegations and custom-based arguments.
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