Case Digest (G.R. No. 176943)
Facts:
The case involves petitioners Danilo Aluad, Leonora Aluad, Divina Aluad, Prospero Aluad, and Connie Aluad against respondent Zenaido Aluad. The events trace back to the familial relationships and property ownership involving their mother, Maria Aluad, and respondent Zenaido, who were both raised by childless spouses Matilde and Crispin Aluad. Crispin owned six lots in Pilar Cadastre, Capiz. After his death, Matilde adjudicated these lots to herself. On November 14, 1981, Matilde executed a "Deed of Donation of Real Property Inter Vivos" in favor of Maria, covering all six lots. The deed stipulated that the donation would take effect upon Matilde's death, and if Maria predeceased Matilde, the donation would be rescinded.
On September 30, 1986, Original Certificates of Title for Lot Nos. 674 and 676 were issued in Matilde's name. Subsequently, on August 26, 1991, Matilde sold Lot No. 676 to Zenaido. Matilde executed a last will and testament on January 14, ...
Case Digest (G.R. No. 176943)
Facts:
Background and Ownership of the Properties
- Crispin Aluad owned six lots (Lot Nos. 674, 675, 676, 677, 680, and 682) in Pilar, Capiz.
- After Crispin's death, his wife Matilde Aluad adjudicated the lots to herself.
Deed of Donation
- On November 14, 1981, Matilde executed a "Deed of Donation of Real Property Inter Vivos" in favor of Maria Aluad (petitioners' mother), covering all six lots.
- The Deed of Donation stated that the donation would take effect upon Matilde's death. It also provided that if Maria died before Matilde, the donation would be rescinded. Matilde retained the right to use, encumber, or dispose of the properties during her lifetime.
Subsequent Transactions
- On September 30, 1986, Original Certificates of Title for Lot Nos. 674 and 676 were issued in Matilde's name.
- On August 26, 1991, Matilde sold Lot No. 676 to respondent Zenaido Aluad via a Deed of Absolute Sale.
- On January 14, 1992, Matilde executed a last will and testament, devising Lot Nos. 675, 677, 682, and 680 to Maria, and Lot No. 674 to Zenaido.
Deaths and Filing of the Complaint
- Matilde died on January 25, 1994, and Maria died on September 24, 1994.
- On August 21, 1995, Maria's heirs (petitioners) filed a complaint for declaration and recovery of ownership and possession of Lot Nos. 674 and 676, alleging that they had possessed the lots since 1978 and that Zenaido had unlawfully taken possession in 1991.
Trial Court Decision
- The Regional Trial Court (RTC) ruled in favor of petitioners, declaring them the rightful owners of Lot Nos. 674 and 676, ordering Zenaido to deliver possession and pay damages.
Court of Appeals Decision
- The Court of Appeals reversed the RTC decision, holding that the Deed of Donation was a donation mortis causa, not inter vivos, and thus void for failing to comply with the formalities of a will. It declared Zenaido the rightful owner of Lot No. 676 but did not rule on Lot No. 674, as Matilde's will had not been probated.
Issue:
- Whether the Deed of Donation was a donation inter vivos or mortis causa.
- Whether Zenaido is the rightful owner of Lot No. 676 based on the Deed of Sale executed by Matilde.
- Whether petitioners are the rightful owners of Lot No. 674.
- Whether the issuance of a writ of execution pending appeal was proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)