Case Digest (G.R. No. 213001)
Facts:
Lauro Cardinez, Isidro Cardinez, Jesus Cardinez, Virgie Cardinez, Flora Laconsay and Aida Dela Cruz v. Spouses Prudencio and Cresencia Cardinez, G.R. No. 213001, March 25, 2024, the Supreme Court Second Division, Hernando, J., writing for the Court.
The dispute concerns a 1,950-square meter parcel in Brgy. Sta. Cruz, Bacnotan, La Union originally owned by the late Simeona Cardinez and thereafter inherited by her sons Prudencio, Florentino and Valentin, who agreed to a partition and had TCT No. T-26701 issued in their names on April 23, 1986. Prudencio’s share (the middle portion) was entered under Tax Declaration No. 18237.
In 1994 Valentin asked Prudencio to donate a ten-square-meter portion allegedly encroached by Valentin’s balcony; Prudencio and his wife Cresencia (respondents) claim they were told by Valentin that the paper to be signed concerned a partition and title cancellation, and they signed without reading because they trusted him and could not understand the English document. They were not given a copy. Fourteen years later Prudencio learned a survey was being done and discovered, through petitioners (Valentin’s children), that a notarized Deed of Donation dated April 26, 1994 had been recorded transferring the shares to petitioners; subsequent title entries showed petitioners as owners (TCT No. T-40459).
Respondents filed a barangay complaint unsuccessfully and then, on November 19, 2008, filed a Complaint for Annulment of Document with Recovery of Possession and Damages in RTC Branch 66, San Fernando City (Civil Case No. 7449), alleging Valentin induced them by misrepresentation to sign a Deed of Donation. At trial respondents presented TCT No. T-26701, TD No. 18237, the Deed of Donation, an affidavit of Valentin (dated 1982) and a survey plan; Prudencio testified he and Cresencia only completed Grade 3, that they did not understand the document, and that the notary did not explain it. Petitioners countered they validly acquired the land by donation, produced TCT No. T-40459 and tax declarations in their names, and had the notary Mario G. Rodriguez testify he notarized the parties’ appearances; one petitioner admitted his mother Eufrosina (alleged signatory) died in 1985.
The RTC denied petitioners’ Demurrer to Evidence and, in its February 28, 2012 Decision, found respondents proved the Deed of Donation was executed through fraud and declared the deed voidable and ordered reconveyance and reinstatement of the tax declaration. Petitioners appealed to the Court of Appeals (CA).
In its September 30, 2013 Decision, the CA affirmed the RTC on the facts but modified the legal effect, holding the Deed...(Pro-only)
Issues:
- Whether the Deed of Donation of real property executed by Prudencio, Valentin and Florentino in favor of petitioners is valid.
- Assuming a defect in Prudencio’s consent to the Deed of Donation, whether the donation is void or merely voidable.
- Assuming a defect in consent, whether respondents’ action is already barred by prescription given that the deed was executed on April 26, 1994 and the compla...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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