G.R. No. L-21676 - Aldaba vs. Court of Appeals

Petitioners Vicente Aldaba and Jane Aldaba (father and daughter) sought review of the Court of Appeals decision affirming the Court of First Instance of Manila’s ruling in Civil Case No. 41260.
The dispute arose over two lots located at 427 Maganda Street, Santa Mesa, Manila, originally belonging to Belen Aldaba, a wealthy, childless woman from Malolos, Bulacan who died on February 25, 1955.
Presumptive heirs to Belen Aldaba’s estate were her surviving husband, Estanislao Bautista, and her brother, Cesar Aldaba.

During World War II, Vicente Aldaba and his daughter Jane lived in Malate, Manila, where Belen Aldaba sought medical advice and treatment from them.
After Vicente Aldaba’s residence was destroyed in 1945, Belen Aldaba invited Vicente and Jane to live in one of her two houses on the lots now in controversy; they accepted and actually occupied the house until 1957.
Jane Aldaba later became Belen’s personal physician until Belen’s death in 1955.

On June 24, 1955, Belen’s heirs executed an extrajudicial partition deed allotting the two lots in question to Cesar Aldaba.
On August 26, 1957, Cesar Aldaba and Emmanuel Bautista (grandson of Bautista) executed a deed of exchange whereby Cesar ceded the lots to Emmanuel Bautista in exchange for another property.
Titles to the original lots were cancelled and new Transfer Certificates of Title (TCT Nos. 49996 and 49997) were issued in Emmanuel Bautista’s name.

Emmanuel Bautista demanded that Vicente Aldaba vacate the property; upon refusal, he filed an ejectment case.
Petitioners filed Civil Case No. 41260 on August 22, 1959, against Cesar Aldaba, Emmanuel Bautista, and the Register of Deeds to nullify the extrajudicial partition and to declare the lots owned by petitioners. They sought cancellation of TCTs issued to Emmanuel Bautista and issuance of new titles in their name.
The trial court dismissed the complaint, holding that if Belen intended to convey the properties to Vicente and Jane Aldaba, the conveyance was a donation inter vivos which required a public instrument under Article 749 of the Civil Code to be valid. The court recognized Emmanuel Bautista as absolute owner but allowed petitioners to stay until reimbursed P5,000 for improvements without obligation to pay rental before such reimbursement.
The Court of Appeals affirmed the decision, increasing the reimbursement from P5,000 to P8,000, but ruling otherwise against petitioners.
Petitioners filed a motion for reconsideration which was denied, leading to the present petition before the Supreme Court.

Whether the Court of Appeals erred in affirming the Court of First Instance’s dismissal of petitioners’ complaint.
Whether the donation made by Belen Aldaba to petitioners was a donation inter vivos requiring a public instrument under Article 749 of the Civil Code, or a donation “con causa onerosa” governed by Article 733 not requiring a public instrument.
Whether the lots in question were validly donated to petitioners in consideration of services rendered to Belen Aldaba.
Whether petitioners should be declared absolute owners of the disputed properties.
Whether the courts wrongly considered testimonies that were previously stricken out.