Facts:

The case is entitled Doroteo Banawa, Juliana Mendoza, Casiano Amponin, and Glicería Abrenica vs. Primitiva Mirano, Gregoria Mirano, Juana Mirano, and Marciano Mirano, which was decided by the Supreme Court of the Philippines on May 16, 1980 (G.R. No. L-24750). It revolves around two parcels of land in Batangas claimed by the respondents, who are the heirs of Maria Mirano, against the petitioners, who are the surviving relatives and successors of Doroteo Banawa and Juliana Mendoza.

The controversy began when Maria Mirano, who was taken in by the couple Banawa and Mendoza in 1911, lived with them until her death. She was treated like their child and supported by them. Upon her death in 1949, the respondents claimed ownership of the land where Maria Mirano had lived. The two parcels in question were identified as the Iba property and the Carsuche property. The respondents argued that both parcels belonged to Maria Mirano as her inheritance and that any deeds of sale to the petitio

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Facts:

Parties and Procedural History

• The petitioners are Doroteo Banawa, Juliana Mendoza, and, after their deaths, their substituted successors Casiano Amponin and his wife Gliceria Abrenica.
• The respondents are Primitiva Mirano, Gregoria Mirano, Juana Mirano, and Marciano Mirano, asserting title as heirs of Maria Mirano.
• The case is a petition for review by certiorari of a decision of the Court of Appeals rendered on April 12, 1965, which itself affirmed the decision of the trial court.
• The underlying dispute involves the ownership of two parcels of land in Taal, Batangas—the “Iba Property” (Lot No. 1) and the “Carsuche Property” (Lot No. 2).

Description and History of the Properties

• Iba Property (Lot No. 1)
• A parcel of sugar land situated in Barrio Iba, Taal, Batangas, with an approximate area of 44,200 square meters.
• Bounded by natural and neighboring properties as described in the complaint and evidenced by Tax Declaration No. 25994.
• Originally owned by Placido Punzalan, acquired by the parties on May 5, 1921 through a deed of sale, with the transaction ostensibly executed in favor of Maria Mirano.
• The petitioners argue that the funds used for the purchase were loans given to Placido Punzalan by the spouses (Doroteo Banawa and Juliana Mendoza), who later claimed that the money was donated to Maria Mirano.

Transactional Background and Alleged Donation

• In circa 1911, Maria Mirano, a relative of Juliana Mendoza, was taken in and reared by the spouses who, being childless, treated her as their own.
• The spouses supported Maria by providing education, money, clothes, and jewelry; in return, she assisted with household chores.
• The parties later engaged in business ventures (e.g., a store in barrio Lutucan) which enabled the acquisition of the disputed lands.
• The transaction for the Iba Property involved:
• A deed of sale from Placido Punzalan to Maria Mirano executed in 1921 for the amount of P2,000.00.
• An underlying arrangement wherein the spouses allegedly provided the funds (or equivalently, the credit via pre-existing debts) used by Maria Mirano to purchase the property.
• The inherent controversy regarding whether this arrangement constitutes a donation inter vivos or a simulated sale to disguise a donation mortis causa.
• With respect to the Carsuche Property:
• Testimonies established that in December 1935, a document (allegedly a public instrument) was executed indicating the sale of the property to Maria Mirano.
• Opposing evidence presented by the petitioners suggests that a private document was drawn up and that, later on in 1940, the spouses acquired the property through a duly registered deed of sale.
• The conflicting evidences gave rise to the claim that the petitioners acquired the property by adverse possession under the doctrine of acquisitive prescription.

Claims, Errors, and Points of Contention

• The petitioners assigned several errors in the Court of Appeals ruling, including:
• Misinterpreting the nature of the transaction for the Iba Property as a donation inter vivos instead of a donation mortis causa.
• Applying a too-literal interpretation of Article 632 of the Old Civil Code, disregarding the requirement of actual or constructive delivery in verbal donations.
• The application of the “exceptive clause” under Article 1448 of the Civil Code regarding implied trust in the present context.
• Non-application of Section 5, Rule 100 of the Old Rules of Court on the basis of legal adoption issues.
• Ruling that the 1940 deed of sale affecting the Carsuche Property did not impair the purported earlier sale to Maria Mirano.
• The pivotal factual issue revolves around the true intention of the parties in executing the contracts, whether to effect a sale with subsequent donation of funds (or debt credits) or to execute a clandestine arrangement for donation.
• Additional factual findings include that Maria Mirano, who was once the purported owner, died on July 31, 1949, and that possession by the petitioners (in the case of the Carsuche Property) continued uninterrupted for a period which underpins the claim to acquisitive prescription.

Issue:

• Whether the transfer of the Iba Property to Maria Mirano should be treated as a donation inter vivos or a simulated sale-donation arrangement.
• Whether the petitioners’ interpretation of Article 632 of the Old Civil Code, particularly regarding the requirement for simultaneous (actual or constructive) delivery in an oral donation of personal property, is correct.
• Whether the alleged simulation of a contract—purporting to mask a donation by using documents of sale—renders the transactions null and void.
• Whether the petitioners may validly claim ownership by acquisitive prescription over the Iba Property given the absence of a just title and the timing of possession (before and after Maria Mirano’s death).
• Whether the 1940 deed of sale regarding the Carsuche Property, duly registered and giving the petitioner-spouses actual and adverse possession, invalidates the earlier purported sale to Maria Mirano.
• Whether Section 5, Rule 100 of the Old Rules of Court applies to protect the rights of the donor-spouses in the context of legal adoption, considering that Maria Mirano was not legally adopted.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)