Case Digest (G.R. No. 159567)
Facts:
In Catalan v. Basa (G.R. No. 159567, July 31, 2007), the petitioners, heirs of Feliciano Catalan through the Bank of the Philippine Islands (BPI) as guardian, sought nullity of an Absolute Deed of Donation executed on June 16, 1951 in favor of Mercedes Catalan. Feliciano, discharged from military service on October 20, 1948 due to a schizophrenic reaction, catatonic type, married Corazon Cerezo on September 28, 1949. The 1951 donation of half of an 801-sqm parcel in Barangay Basing, Binmaley, Pangasinan, was registered and led to separate tax declarations for both halves. In December 1953, the Court of First Instance adjudged Feliciano incompetent and appointed BPI as guardian. Mercedes sold the donated portion to her children Delia and Jesus Basa on March 26, 1979; registration only occurred on February 20, 1992. Acting as guardian, BPI filed on April 1, 1997 a complaint for Declaration of Nullity of Documents, Recovery of Possession and Ownership, and Damages, alleging FeliciaCase Digest (G.R. No. 159567)
Facts:
- Background of Feliciano Catalan
- October 20, 1948: Discharged from military service due to “schizophrenic reaction, catatonic type” (Certificate of Disability for Discharge).
- September 28, 1949: Married Corazon Cerezo.
- 1951 Donation and Registration
- June 16, 1951: Executed Absolute Deed of Donation, conveying one-half of a parcel in Brgy. Basing, Binmaley, Pangasinan, to his sister Mercedes Catalan.
- Register of Deeds: Registered donation; BIR cancelled Tax Declaration No. 2876 and issued Nos. 18080 (Mercedes, 400.50 sqm) and 18081 (Feliciano, 400.50 sqm).
- Guardianship Proceedings and Subsequent Donations
- December 11–22, 1953: People’s Bank & Trust Co. filed petition; court adjudged Feliciano incompetent and appointed the bank (now BPI) guardian.
- November 22, 1978 to February 14, 1983: Feliciano and Corazon donated other lots under OCT No. 18920 to various children (Eulogio, Alex, Librada, Zenaida, Florida).
- Sale to the Basa Respondents
- March 26, 1979: Mercedes Catalan sold her half-share to her children Delia and Jesus Basa.
- February 20, 1992: Deed of Absolute Sale registered; Tax Declaration No. 12911 issued to Delia and Jesus Basa.
- Nullity and Recovery Proceedings
- April 1, 1997: BPI, as guardian, filed for nullity of the 1951 donation, recovery of possession, ownership, and damages—alleging Feliciano’s incapacity and fraud in the subsequent sale.
- August 14, 1997: Feliciano died; complaint amended substituting his heirs for BPI.
- Trial Court Decision
- December 7, 1999: RTC Branch 69, Lingayen dismissed complaint—upheld presumption of Feliciano’s sanity and due execution of the 1951 donation; declared Delia and Jesus Basa lawful owners; awarded P10,000 attorney’s fees.
- Court of Appeals Decision
- CA-G.R. CV No. 66073 affirmed (May 2004): Held petitioners failed to prove mental incapacity at donation date; all formalities of donation and subsequent sale complied with; notarized documents presumed regular; no evidence of fraud.
- Petition to the Supreme Court
- Petitioners raised four issues: proof of insanity, admissibility of medical certificates, validity of sale by Mercedes, and prescription/laches.
Issues:
- Whether the Court of Appeals erred in holding that petitioners failed to prove Feliciano’s mental incapacity at the time of the June 16, 1951 donation.
- Whether the Certificate of Disability for Discharge and Board of Medical Officers’ report are admissible in evidence.
- Whether the Court of Appeals erred in upholding the March 26, 1979 sale by Mercedes Catalan to Delia and Jesus Basa.
- Whether Civil Case No. 17666 is barred by prescription and laches under Article 1391 of the New Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)