G.R. No. L-10058 - Asuncion vs. Benalisa

The case was initiated by plaintiffs Severo Asuncion and Pascuala Ilustre in the Court of First Instance of Rizal on August 7, 1950.
The subject matter involves the recovery of title to and possession of certain pieces of real property located in Tanay, Rizal province.
The property was alleged to have been acquired by plaintiff Pascuala Ilustre by way of donation propter nuptias executed by defendant Juan Benalisa on August 26, 1927.

Defendants (Juan Benalisa and Lucia Suarez) admitted that a donation propter nuptias was executed in favor of Pascuala Ilustre and her first husband, Pablo Benalisa.
It was stipulated that:

The donation was executed on August 27, 1927.
Plaintiff Pascuala, together with her first husband Pablo, were married in the month following the donation execution.
Pablo Benalisa died on June 28, 1929.

After Pablo’s death, plaintiff Pascuala Ilustre came to reside with Severo Asuncion.
There existed a longstanding enmity, as approximately twenty years earlier, the plaintiffs had attempted to take the life of defendant Juan Benalisa.
Due to this incident, defendant Juan Benalisa had persistently refused to comply with the terms of the donation, thereby preventing the plaintiffs from taking possession of the property.

The defendants further claimed that the plaintiffs lost any right or interest in the property by failing to claim it within the statutory period.

On a pre-set hearing date, both parties submitted a stipulation of facts which the court approved without opposition.
Following the approval, the defendants moved for a continuance, which the court granted.
On the rescheduled hearing, rather than conducting a full trial, the court ordered the parties to submit memoranda on whether the donation remained “valid and subsisting.”
After reviewing the memoranda, the trial court rendered a decision declaring the plaintiffs as the owners of the property and ordered them to be given possession.

The defendants appealed to the Court of Appeals, which certified the appeal as involving questions of law only.
Central to the appeal was the issue of prescription due to the defendants’ alleged long-term refusal to honor the donation, claimed to have begun more than 20 years prior to the institution of the lawsuit.

Whether the defense of prescription under section 40 of Act No. 190 is valid, considering the defendants’ alleged persistent non-compliance with the donation terms for over 20 years.
Whether the lower court erred in not receiving evidence on the defendants’ allegations of adverse possession and repudiation of the trust created by the donation.
Whether the ruling of the trial court, which was based solely on the parties’ stipulation of facts and subsequent memoranda, is sustainable given that a full trial for the reception of proof was never conducted.