Facts:

The case involves Vicente Aldaba and Jane Aldaba as petitioners against the Court of Appeals, Cesar Aldaba, and Emmanuel Bautista as respondents. The events in question date back to February 25, 1955, the day Belen Aldaba, a wealthy woman from Malolos, Bulacan, passed away. She left a husband, Estanislao Bautista, and a brother, Cesar Aldaba, as her presumptive heirs, having no children. Among her properties were two lots located at 427 Maganda Street, Santa Mesa, Manila.

Petitioners Vicente and Jane Aldaba, who are father and daughter, took residence in one of Belen Aldaba’s houses following the destruction of their home during World War II. They lived there until an ejectment case was filed against them by Emmanuel Bautista in 1957. Vicente Aldaba was not only a medical advisor to Belen but also was later joined by Jane, who became her personal physician until her death in 1955.

Following Belen’s demise, her heirs executed a deed of extrajudicial partition on June 24, 1955, w

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Facts:

Background on the Deceased and Heirship

• Belen Aldaba, a wealthy woman from Malolos, Bulacan, died on February 25, 1955.
• As a childless woman, her presumptive heirs were her surviving husband, Estanislao Bautista, and her brother, Cesar Aldaba.
• Among her properties were two lots located at 427 Maganda Street, Santa Mesa, Manila.

Relationships and Occupancy

• Petitioners Dr. Vicente Aldaba and his daughter Jane Aldaba had a longstanding association with Belen, providing medical advice and assistance.
• After Dr. Vicente Aldaba’s house burned during the liberation of Manila in 1945, Belen invited him and his daughter to live in one of her houses constructed on the two lots.
• The petitioners resided in the house on the said lots until an ejectment action was initiated by Emmanuel Bautista in 1957.

Extrajudicial Partition and Subsequent Transactions

• On June 24, 1955, the presumptive heirs, Estanislao Bautista and Cesar Aldaba, executed a deed of extrajudicial partition in which Cesar Aldaba was allotted the two disputed lots.
• Later, on August 26, 1957, Cesar Aldaba and Emmanuel Bautista (a grandson of Estanislao Bautista) executed an exchange deed, ceding the lots to Emmanuel Bautista in return for another lot located at San Juan, Rizal.
• Following these transactions, the Register of Deeds of Manila cancelled the previous Transfer Certificates of Title (TCT Nos. 1334 and 1335 in the name of Belen Aldaba) and issued new TCTs (Nos. 49996 and 49997) in the name of Emmanuel Bautista.

Initiation of Litigation

• After Emmanuel Bautista demanded that Dr. Vicente Aldaba vacate the lots, and upon his refusal, an ejectment case was filed against him in the City Court of Manila.
• Without awaiting the outcome of the ejectment case, on August 22, 1959, the petitioners filed a complaint in the Court of First Instance of Manila (Civil Case No. 41260) against Cesar Aldaba, Emmanuel Bautista, and the Register of Deeds.
• The petitioners sought the cancellation of the extrajudicial partition (and related transfers) and the issuance of new TCTs in their names, arguing that they were the true owners of the disputed lots based on a presumed donation by Belen Aldaba.

Alleged Donation and Evidence Presented

• The petitioners contended that Belen Aldaba, in compensation for the long-term, uncompensated personal services rendered by Dr. Vicente Aldaba and Jane Aldaba, had effectively donated the lots to them.
• In support of their claim, petitioners introduced Exhibit 6—a note allegedly written on June 18, 1953—which stated, “Jane, Huag kayong umalis diyan. Talagang iyan ay para sa inyo. Alam nila na iyan ay sainyo. - Belen A. Bautista.”
• They also relied on Exhibit 7—a letter dated June 27, 1956—arguing that it demonstrated a recognition by the opposing party of the petitioners’ interest in the property.

Decisions of Lower Courts

• The Court of First Instance of Manila eventually dismissed the complaint, holding that if donation had been intended by Belen Aldaba, it would have been considered a donation inter vivos; thus, it required a public instrument under Article 749 of the Civil Code.
• The trial court’s decision further held Emmanuel Bautista to be the absolute owner of the property, subject only to an obligation to reimburse the petitioners a modest amount (initially P5,000, later raised to P8,000 by the Court of Appeals).
• The petitioners’ action was therefore dismissed, and the decision of the Court of Appeals, which affirmed the dismissal, was ultimately challenged in the present petition for review.

Issue:

Validity and Nature of the Alleged Donation

• Whether the note in Exhibit 6 constitutes a valid donation of the two lots by Belen Aldaba to petitioners.
• Whether the donation, if it existed, was a donation inter vivos or a donation cum causa onerosa (for valuable consideration).

Evidentiary Sufficiency on the Transaction

• Whether the evidence, including Exhibits 6 and 7, sufficiently demonstrated that Belen voluntarily and effectively disposed of the property in favor of the petitioners.
• Whether the alleged donation was supported by an implied or express contract, particularly in view of the petitioners’ rendered services.

Compliance with Formal Requirements

• Whether Belen Aldaba’s alleged donation was valid since, if executed as a donation inter vivos, it should have been formalized by a public instrument pursuant to Article 749 of the Civil Code.
• Whether the absence of any notarial document from 1945 to 1955 undermines the petitioners’ claim.

Consideration for the Donation

• Whether the long-term, uncompensated services rendered by petitioners could be regarded as sufficient consideration (i.e., as an onerous cause) for the donation.
• Whether there was any indication, either express or implied, of an agreement wherein Belen expected compensation, thus satisfying the requirements for a donation cum causa onerosa.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)