Title
Aznar vs. Sucilla
Case
G.R. No. L-10806
Decision Date
Jan 27, 1958
Aznar heirs contested a void spousal donation of conjugal land; SC ruled donation invalid, entitling heirs to share.
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Case Digest (G.R. No. L-10806)

Facts:

  1. Parties Involved:

    • Plaintiffs-Appellants: David Aznar et al. (nephews and nieces of the late Inocente Aznar).
    • Defendant-Appellee: Asuncion Sucilla (widow of Inocente Aznar).
  2. Subject Property:

    • A parcel of land with an area of 4.8007 hectares, described in Transfer Certificate of Title No. 15195, located in Quezon Province.
    • The property was conjugal property of Inocente Aznar and Asuncion Sucilla.
  3. Deed of Donation:

    • On March 15, 1948, Inocente Aznar executed a deed of donation in favor of his wife, Asuncion Sucilla.
    • The deed was titled "Kasulatan ng Pagkakaloob" and described the property as a coconut land.
    • The deed was notarized and acknowledged before a notary public.
  4. Death of Inocente Aznar:

    • Inocente Aznar died on March 22, 1948, shortly after executing the deed of donation.
  5. Plaintiffs' Claim:

    • Plaintiffs, as heirs of Inocente Aznar, filed a complaint on December 15, 1952, seeking partition of the property and an accounting of its proceeds.
    • They argued that the property should be divided between Asuncion Sucilla and themselves as heirs.
  6. Defendant's Defense:

    • Asuncion Sucilla claimed that the property had already been donated to her through the deed of donation, and thus, the plaintiffs had no right to claim any share.
  7. Trial Court Decision:

    • The trial court ruled in favor of Asuncion Sucilla, holding that the deed of donation was a valid donation inter vivos, which transferred ownership of the property to her.

Issue:

  1. Whether the deed of donation executed by Inocente Aznar in favor of Asuncion Sucilla is valid and effectively transferred ownership of the property.
  2. Whether the deed of donation is a donation inter vivos or mortis causa.
  3. Whether the plaintiffs, as heirs of Inocente Aznar, are entitled to a share in the property.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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