G.R. No. L-9113, December 24, 1915
BENITO LOPEZ, administrator of the estate of Marcela Emradura, deceased, plaintiff-appellee, vs. TOMAS VALDEZ, defendant-appellant.

FACTS:
Benito Lopez, as the administrator of the estate of Marcela Emradura, filed an action against Tomas Valdez to recover possession of a parcel of land, upon payment of ₱30. The trial court ruled in favor of Lopez, ordering Valdez to deliver possession of the land upon payment of the amount and directing the cancellation of the registration of the portion of land in dispute from the title of Gregorio San Agustin. Valdez appealed, assigning several errors.

ISSUE:
1. Whether the plaintiff-appellee Benito Lopez validly established his authority as administrator of the estate of Marcela Emradura.
2. Whether the trial court committed reversible error in its procedure regarding objections to secondary evidence of written documents.
3. Whether the plaintiff-appellee sufficiently proved the right to possession of the land.

RULING:
The Supreme Court REVERSED the trial court’s decision and DISMISSED the complaint on the merits.

1. Lack of Proof of Authority: The record contained no evidence that Benito Lopez was ever appointed administrator of Marcela Emradura’s estate. The absence of such proof alone warranted the reversal of the judgment.

2. Improper Procedure on Objections: The trial court erred in deferring rulings on objections to secondary evidence of written documents without resolving them during trial. This deprived the appellant of the opportunity to properly rebut evidence or adjust his defense, prejudicing his substantial rights.

3. Insufficient Evidence for Possession: The evidence presented did not adequately establish the estate’s right to possession of the land. The Court refrained from discussing the evidence in detail but concluded that the plaintiff failed to meet the burden of proof.

The complaint was dismissed without costs.