Title
Bautista vs. Sabiniano
Case
G.R. No. L-4236
Decision Date
Nov 20, 1952
A conditional donation to minors was deemed invalid due to improper acceptance by legal representatives; deemed onerous and mortis causa, not inter vivos.
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Case Digest (G.R. No. L-4236)

Facts:

  1. Parties Involved:

    • Plaintiffs-Appellees: Asteria Bautista, Maxima Lomibao, Francisco Lomibao, Jose Lomibao, Felisa Lomibao, and Paulina Lomibao (lawful heirs of Alberto G. Bautista).
    • Defendants-Appellants: Epifanio Sabiniano (as guardian ad litem of minors Marcelina Sabiniano and Candida Sabiniano), Marcelina Sabiniano, Candida Sabiniano, and Alfredo de Guzman (represented by his mother Leonora Cansino).
  2. Subject Matter:

    • The case involves a Deed of Conditional Donation executed by Alberto G. Bautista on September 7, 1948, in favor of:
      • Marcelina Sabiniano and Candida Sabiniano (minors, represented by their father Epifanio Sabiniano).
      • Atanacio Lomibao (of legal age).
      • Alfredo de Guzman (minor, represented by his mother Leonora Cansino).
  3. Conditions of the Donation:

    • The donor, Alberto G. Bautista, reserved the right to:
      • Dispose of the properties during his lifetime.
      • Use the products derived from the properties.
      • Require the donees to pay his debts and funeral expenses upon his death.
  4. Trial Court Decision:

    • The Court of First Instance of Pangasinan ruled that the donation was invalid as to Marcelina Sabiniano, Candida Sabiniano, and Alfredo de Guzman (minors) due to lack of proper acceptance by their legal representatives.
    • The donation was valid as to Atanacio Lomibao, who was of legal age at the time of acceptance.
  5. Appeal:

    • Epifanio Sabiniano appealed on behalf of his minor children, Marcelina and Candida Sabiniano. Leonora Cansino (mother of Alfredo de Guzman) did not appeal.

Issue:

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Ruling:

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Ratio:

  1. Donation Requirements:

    • A valid donation requires acceptance by the donee. For minors, acceptance must be made by their legal representatives. Failure to comply with this requirement renders the donation invalid.
  2. Conditional and Onerous Donations:

    • A donation is onerous if it imposes obligations on the donee. In this case, the donees were required to pay the donor’s debts and funeral expenses, making the donation onerous.
  3. Reservation of Rights:

    • If the donor reserves the right to dispose of the properties and benefit from their products during his lifetime, the donation is not inter vivos but mortis causa. Such a donation must comply with the formalities of a will under the law.
  4. Revocability of Donations:

    • A donation is irrevocable except in specific instances provided by law (e.g., ingratitude, non-compliance with conditions). However, if the donor reserves the right to revoke or dispose of the properties, there is no valid donation.
  5. Legal Representation of Minors:

    • Minors cannot validly accept donations without the proper representation of their legal guardians. Any acceptance made on their behalf must comply with legal requirements to be valid.

Conclusion:

The Supreme Court affirmed the trial court’s decision, holding that the conditional donation was invalid as to the minor donees due to improper acceptance. The donation was deemed onerous and not inter vivos, as the donor reserved extensive rights over the properties during his lifetime. The ruling underscores the importance of proper acceptance and compliance with legal formalities in donations, especially when minors are involved.


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