Austin Craig v. Servulo Leuterio

Summary

Estate administrator Austin Craig sued Servulo Leuterio to recover property belonging to deceased Ramon Valencia's estate. The dispute centered on a 1893 deed allegedly signed by defendant conveying land to the deceased. While the Supreme Court found the evidence supported the deed's authenticity and validity between the parties despite lacking notarization, the Court reversed the favorable lower court judgment because plaintiff failed to prove his appointment as judicial administrator. The Court held that a non-notarized deed is valid between parties under Civil Code principles, and that recording requirements don't apply to disputes between original parties. However, without proof of administrative authority, plaintiff lacked standing to bring the action. The case was remanded for new trial to allow plaintiff to remedy this evidentiary defect while preserving the existing evidence record.