Facts:

The case in question stems from an appeal filed by Felix Atacador, the administrator of the intestate estate of the deceased Florentino Atacador and Victoria Payumo. The appeal was against defendants Hilarion Silayan, Rosario Payumo, and Eduardo Payumo. The ruling in dispute was rendered by the Court of First Instance of Nueva Ecija on April 29, 1939. The plaintiff sought to recover ownership and possession of twenty parcels of land jointly described in the complaint, as well as damages and a request for the appointment of a receiver for said properties during the proceedings. The defendants denied the key allegations of the complaint, claiming ownership over certain parcels by donation from the deceased owners, specifically indicating that Rosario Payumo and Eduardo Payumo are the niece and grandson of Florentino Atacador and Victoria Payumo, respectively. They asserted that the disputed properties are all that remained from the deceased’s estate.

The parties engaged in stipula

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Facts:

Parties and Representations

• Plaintiff and Appellant:

- Felix Atacador, Administrator of the intestate estates of the deceased Florentino Atacador and Victoria Payumo. - Hilarion Silayan, Rosario Payumo, and Eduardo Payumo.

Nature of the Case and Relief Sought

• The plaintiff initiated a civil action seeking:

- Recovery of ownership and possession of twenty parcels of land described in Exhibit A of the complaint. - Indemnity for damages arising from the disputed ownership of the properties. - Appointment of a receiver to manage the properties during litigation.

Defendants’ Contentions and Special Defenses

• The defendants specifically denied the material allegations contained in the complaint.
• They interposed various special defenses, the most significant being:

- The claim that Rosario Payumo and Eduardo Payumo, being niece and grandson respectively of the decedents, are rightful owners by virtue of a donation from the deceased. - As to parcels 18 and 20, they alleged these were the remaining properties left by Florentino Atacador, offered to the plaintiff prior to litigation. - As to parcel 19, it was asserted to be the only property left by Victoria Payumo for her surviving nephews.

Stipulations and Agreements Between Parties

• A stipulation was entered whereby:

- The pieces of land in items 18 and 20 of the submitted inventory (Exhibit A) were to be turned over to the plaintiff. - The case be dismissed with respect to certain defendants without assignment of costs. - All properties not expressly mentioned in the deed of donation were temporarily dismissed from dispute. - Acceptance of facts as alleged in the complaint (particularly pertinent paragraphs 1 to 4). - Authenticity of the deed of donation dated October 14, 1931, and subsequent transfer of titles (Torrens titles Nos. 5558, 5559, 5560, and 9557). - Evidence that Eduardo Payumo had paid the land tax since 1932 and that tax declarations had been transferred to his name since December 1931. - That Eduardo Payumo had complied with the conditions imposed by the donation, including providing a share of the land's produce for the donor’s support. - An agreement for rendering a decision on the disputed properties without incurring costs for him.

The Disputed Donation

• Central to the controversy was the validity of the deed of donation executed on October 14, 1931, by the spouses Florentino Atacador and Victoria Payumo in favor of Eduardo Payumo.
• The plaintiff contested the donation by arguing that:

- At the time of execution and acceptance of the deed, Eduardo Payumo was a minor (only twenty years old), rendering the donation void. - The donation was subsequently confirmed and ratified by the parties’ conduct, as indicated by actions undertaken after Eduardo reached majority (in 1932).

Administrative and Procedural Developments

• After Eduardo Payumo attained majority:

- He assumed administration of and enjoyed the fruits of the donated properties. - He cancelled the original certificate of title (No. 4841) and secured new transfer certificates (Torrens titles Nos. 5558, 5559, 5580, and 5561).

Alleged Clerical Error in the Appellate Decision

• The attorneys for the appellees later pointed to an apparent clerical error in the dispositive portion of the decision:

- Parcels 18 and 19 were erroneously adjudicated to the intestate of Florentino Atacador, whereas the stipulations indicated:

Final Outcome as Presented

• The court, after considering all the matters including the dispute over the deed of donation and the noted clerical error, affirmed the appealed decision.
• It was ultimately ruled that:

- The donation executed in favor of Eduardo Payumo was valid. - The allocation of properties should reflect the stipulation regarding the intestates of Florentino Atacador (parcels 13 and 20) and Victoria Payumo (parcel 19).

Issue:

Validity of the Donation

• Whether the deed of donation executed on October 14, 1931, is valid despite being made while the donee, Eduardo Payumo, was a minor.
• Whether the subsequent confirmation and ratification of the donation, upon Eduardo reaching majority and through actions such as tax payments and transfer of titles, legally validate the donation.

Interpretation and Application of the Stipulations

• Whether the parties’ stipulated agreement on the disposition of the parcels, including the specific allocation to the intestates of Florentino and Victoria Payumo, was correctly reflected in the decision.
• How the stipulated conditions influence the overall adjudication of property ownership.

Addressing the Clerical Discrepancy

• Whether the manifested clerical error in the appellate decision—misstating the parcels allocated to the intestates—affects the ultimate disposition of the case.
• The proper corrective measure required to reflect the true intent and stipulation agreed upon by the parties.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)