Samson v. CA - Case Digest
Samson v. CA - Case Digest
Facts:
During the settlement of the intestate estate of Juan Bon Fing Sy, four (4) of
his creditors filed their claims against his estate. Two of them were Felicito and
Celedonia who were siblings; the two other being Eduardo and his mother
Angeles.
Jade, wife of Eduardo and daughter-in-law of Angeles, testified in favor of the
two as she was present when the transaction happened. As for the siblings,
they testified for each other's claim.
Melecia Sy, the surviving spouse of the deceased as administratix, argued the
testimonies of the witnesses were in circumvention of the Dead Man's Statute.
Issues:
Ruling:
1. No, the testimony of Jade did not contravene the Dead Man's Statute.
Relationship to a party has never been recognized as an adverse factor in
determining either the credibility of the witness. The rule renders
incompetent: 1) parties to a case; 2) their assignors; or 3) persons in whose
behalf a case is prosecuted. The rule is exclusive and cannot be construed to
extend its scope by implication so as to disqualify persons not mentioned
therein. Mere witnesses who are not included in the above enumeration are not
prohibited from testifying as to a conversation or transaction between the
deceased and a third person, if he took no active part therein.
Jade was not one of those disqualified and she testified as a witness to the
transaction.
2. No, the testimonies of the siblings for each other did not contravene the
Dead Man's Statute. Felicito’s and Celedonia’s claims against the same estate
arose from separate transactions. Felicito is a third party with respect to
Celedonia’s claim and Celedonia is a third party with respect to Felicito’s
claim. One is not thus disqualified to testify on the others transaction.
In any event, what the Dead Man’s Statute proscribes is the admission
of testimonial evidence upon a claim which arose before the death of the
deceased. Since the separate claims of Felicito and Celedonia are supported by
checks-documentary evidence, their claims can be prosecuted on the bases of
said checks.