G.R. No. L-10806 - Aznar vs. Sucilla

The dispute centers on a deed of donation executed by Inocente Aznar on March 15, 1948, in favor of his wife, Asuncion Sucilla.
The donated property is a parcel of land with an area of 4.8007 hectares, described in Transfer Certificate of Title No. 15195, Quezon province.

Plaintiffs-Appellants: The nephews and nieces of the late Inocente Aznar, who claim their right as heirs to a share in his conjugal property.
Defendant-Appellee: Asuncion Sucilla, the wife of the deceased Inocente Aznar and the donee of the disputed donation.

Inocente Aznar executed the deed of donation during his lifetime, but his death occurred shortly after on March 22, 1948.
The document was notarized by Notary Public Marciano Mopera, and contained the full description of the property along with the signatures, thumb marks, and the attestation of witnesses.
The instrument was explicitly labeled as a "DONACION mortis causa" but was subject to an agreed determination by the court as to whether it should be deemed a donation inter vivos or mortis causa.

On December 15, 1952, the plaintiffs filed a complaint in Civil Case No. 327 before the court of first instance of Quezon, seeking the partition of the conjugal property.
The plaintiffs alleged that despite the donation, the property – being conjugal – should have been divided among the heirs to which they are entitled.
Defendant Asuncion Sucilla admitted that the property was conjugal and acknowledged the familial relationship but contended that the valid donation extinguished any claim of succession by the heirs.

At the hearing, both parties submitted an agreement (convenio) stating that the court should determine whether the donation is inter vivos or mortis causa and apply the relevant law accordingly.
The parties agreed on the good-faith possession of the property by the defendant and on the exclusion of costs.

The trial court ruled in favor of Asuncion Sucilla, holding that the donation was inter vivos, thereby establishing a perfected contract that effectively transferred ownership.
The court reasoned that, having been executed by a public instrument and with formal acceptance by the donee, the donation deed was valid and the plaintiffs, as heirs, could not claim a one-half share of the conjugal property.

Plaintiffs filed a motion for reconsideration, which was denied by the trial court.
Subsequently, the plaintiffs elevated the case on appeal, arguing that the lower court erred both in declaring the donation valid and in absolving the defendant from having to partition the estate.

Whether the deed of donation executed on March 15, 1948, effectively transferred ownership of the property to Asuncion Sucilla.
Whether the manner of the donation, viewed either as inter vivos or mortis causa, meets the legal requirements for validity.

Whether the deed should be characterized as a donation inter vivos or as a donation mortis causa.
The legal consequences of its classification, particularly in light of the provisions under the old Civil Code.

Whether the validity of the donation precluded the nephews and nieces from later claiming their rightful share by succession given that the property was conjugal.
Whether the donation could lawfully operate to divest the heirs of their statutory share, or if it should be set aside for contravening legal provisions.