Case Digest (G.R. No. 171937) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Calanasan v. Dolorito, petitioner Cerila J. Calanasan, represented by her sister Teodora J. Calanasan as attorney-in-fact, filed on August 15, 2002 a complaint for revocation of a conditional donation against respondents Spouses Virgilio and Evelyn C. Dolorito before the Regional Trial Court (RTC) of Malolos City, Bulacan. Cerila, who had reared her orphaned niece Evelyn since childhood, donated in 1982 a mortgaged parcel of land to Evelyn on the condition that Evelyn redeem the P15,000 mortgage and grant Cerila usufructuary rights for life. Evelyn accepted, redeemed the mortgage, transferred title in her name, and upheld the usufruct. Cerila died during trial and her sisters substituted for her. After Cerila rested, respondents successfully moved for demurrer to evidence on the ground that Cerila failed to prove that Evelyn committed any ungrateful acts against her as required by Article 765 of the New Civil Code. The RTC granted the demurrer and dismissed the complaint, fin Case Digest (G.R. No. 171937) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationship
- Petitioner Cerila J. Calanasan (through attorney-in-fact Teodora J. Calanasan) had cared for her orphan niece, Evelyn C. Dolorito, since childhood.
- Respondents are Evelyn C. Dolorito and her husband Virgilio Dolorito.
- Donation and Conditions
- In 1982, Cerila donated to Evelyn a parcel of land then mortgaged for ₱15,000, conditional upon Evelyn’s redemption of the mortgage and Cerila’s usufruct during her lifetime.
- Evelyn accepted the donation, redeemed the mortgage, caused the title’s transfer to her name, and granted Cerila usufructuary rights.
- Proceedings in the Regional Trial Court (RTC)
- On August 15, 2002, Cerila (later substituted by her sisters Teodora and Dolores) filed for revocation of the donation on grounds of ingratitude under Article 765, New Civil Code.
- Respondents denied any ungrateful acts by Evelyn. They filed a demurrer to evidence.
- On September 3, 2004, the RTC granted the demurrer, ruling:
- Ungrateful acts were allegedly by Virgilio, not Evelyn.
- The acts were directed at Teodora (the donor’s sister), not at Cerila.
- Proceedings in the Court of Appeals (CA)
- On September 29, 2005, the CA affirmed the RTC decision but on the ground that the donation was inter vivos and onerous; hence, it was governed by contract law and not subject to revocation under Article 765.
- On March 8, 2006, the CA denied the motion for reconsideration.
- Petition to the Supreme Court
- Petitioner argued Evelyn committed ungrateful acts and violated the deed’s terms by acquiring ownership during the donor’s lifetime.
- Respondents contended that these were factual issues barred by Rule 45 and that the deed only imposed two conditions—redemption and usufruct—which were fully complied with.
Issues:
- Whether the CA erred in ruling that the inter vivos donation’s onerous cause is governed by the rules on contracts, rendering Article 765 inapplicable to its onerous portion.
- Whether factual issues and new arguments on ingratitude and suspensive conditions may be raised for the first time in a Rule 45 petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)