Facts:

In the case of Juliana Abragan et al. vs. Rita G. de Centenera et al., G.R. No. L-22173, decided on September 25, 1924, the plaintiffs, Juliana Abragan and her daughter Julieta Abragan, filed an amended complaint on January 18, 1923, in the Court of First Instance of Camarines Sur. They aimed to recover three parcels of real property from Jose N. Garchitorena, who was the administrator of the estate of the late Andres Garchitorena. The plaintiffs assert that the properties in question rightfully belong to them: Juliana holds the usufruct, while Julieta holds the naked ownership. The properties include a nine-hectare coconut land worth P2,000 and a building lot with a warehouse in Tigaon valued at P1,900, gifted to them by Andres Garchitorena through two deeds executed in February 1920 (later acknowledged to be 1921). However, these gifts were not formally accepted through a public document before the donor’s death. Following the donor's death in 1921, Rita G. de Centenera, a

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Facts:

Parties and Nature of the Case

• Plaintiffs:
• Juliana Abragan
• Julieta Abragan (daughter of Juliana)
• Defendants:
• Rita G. de Centenera (initially acting in her capacity as the sole heir and special administratrix of Andres Garchitorena’s estate)
• Jose N. Garchitorena (administrator of the estate of Andres Garchitorena)
• Relief Sought by Plaintiffs:
• Recovery of three parcels of real property described in the complaint
• Declaration that the properties belong in usufruct to Juliana Abragan, with the naked ownership remaining with Julieta Abragan
• Recovery of a sum of money as damages for the detention of the said properties

Underlying Transactions and Instruments

• Deeds of Gift Executed by Don Andres Garchitorena (deceased):
• Exhibit A:
• Conveys two parcels of property:
• A piece of land (9 hectares) planted with coconut trees located in the barrio of Matacla, municipality of Goa, Camarines Sur, valued at P2,000

ii. A building lot (446 square meters) in the pueblo of Tigaon, containing a warehouse (camarin) for commercial use, valued at P1,900

Post-Death Developments and Subsequent Actions

• After Don Andres’s death (1921):
• Rita G. de Centenera, as the sole heir, initially served as special administratrix
• On April 1, 1921, Rita executed a public document (Exhibit D) acknowledging that her deceased father had made two donations for the benefit of Julieta and Juliana Abragan (only describing the properties in Exhibit A)
• The document was intended to give effect to her father’s expressed wishes
• Administrative Changes:
• Rita ceased to serve as special administratrix after the execution of Exhibit D
• Jose N. Garchitorena was appointed as the new administrator of Andres Garchitorena’s estate
• Dispute:
• The administrator (Jose N. Garchitorena) came into possession of the properties subject to the gifts
• He refused to recognize the validity of the donations as claimed by the plaintiffs
• The plaintiffs instituted the present action to test and obtain recognition of their rights over the disputed properties

Procedural History

• The case was originally filed in the Court of First Instance of the Province of Camarines Sur
• The trial court absolved the defendants from the complaint
• The plaintiffs subsequently appealed the decision seeking relief based on the merits of the donations and their corresponding rights

Issue:

Validity and Formal Effect of the Deeds of Gift

• Whether the deeds of gift (Exhibits A and B) have any legal effect despite not being executed in the public form required by law
• Whether the acceptance by the donees in the absence of formal notarization renders the gifts legally effective

Legal Impact of the Posthumous Ratification

• Whether the public document (Exhibit D) executed by Rita G. de Centenera, as the sole heir, can be construed as ratification or quitclaim of the gifts contained in Exhibit A
• Whether this ratification estops Rita from asserting any rights against the properties specified in Exhibit A

Appropriate Remedy and Procedural Considerations

• Whether the plaintiffs may directly file an action against the administrator to enforce their rights to the properties
• The necessity for the plaintiffs to intervene in the estate administration proceedings to secure recognition of their interests

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)