Case Digest (G.R. No. 159567)
Facts:
Corazon Catalan, Librada Catalan-Lim, Eulogio Catalan, Mila Catalan-Milan, Zenaida Catalan, Alex Catalan, Daisy Catalan, Florida v. Jose Basa, Manuel Basa, Laureta Basa, Delia Basa, Jesus Basa and Rosalinda Basa, G.R. No. 159567, July 31, 2007, Supreme Court First Division, Puno, J., writing for the Court.The dispute concerns ownership of a parcel of land in Barangay Basing, Binmaley, Pangasinan. On June 16, 1951, Feliciano Catalan executed an instrument titled “Absolute Deed of Donation” purporting to donate one-half (400.50 sq. m.) of the parcel to his sister Mercedes Catalan; the donation was registered and corresponding tax declarations were issued. On March 26, 1979, Mercedes sold the donated portion to her children Delia and Jesus Basa; that Deed of Absolute Sale was registered only on February 20, 1992, and Tax Declaration No. 12911 issued in the Basas’ names.
Relevant medical and guardianship events followed: on October 20, 1948 the Board of Medical Officers of the Department of Veteran Affairs issued a Certificate of Disability finding Feliciano suffered from “schizophrenic reaction, catatonic type.” On December 11, 1953, People’s Bank and Trust Co. filed special proceedings to declare Feliciano incompetent; on December 22, 1953 the court ordered adjudication of incompetency and appointed the bank (now BPI) guardian of his estate.
On April 1, 1997, BPI, as guardian, filed a Complaint for Declaration of Nullity of Documents, Recovery of Possession and Ownership, and damages (Civil Case No. 17666) asserting the 1951 donation was void ab initio because Feliciano lacked mental capacity; it sought to annul Mercedes’s title and the subsequent sale. After Feliciano’s death on August 14, 1997, the complaint was amended substituting his heirs as plaintiffs.
On December 7, 1999 the Regional Trial Court (Branch 69, Lingayen, Pangasinan) dismissed the complaint, holding petitioners failed to rebut the presumption of Feliciano’s sanity and upholding the donation and the Basas’ ownership; the RTC ordered plaintiffs to pay attorney’s fees and costs. Docketed as CA-G.R. CV No. 66073, the Court of Appeals affirmed, finding the elements for a valid donation present and that the later sale was valid and carried the evidentiary weight of a notarized public document (citing Garrido v. CA and Salame v. CA). Petitioners then filed a Rule 45 petition for review on certiorari before this Court, raising, among ...(Pro-only)
Issues:
- Did the Court of Appeals err in holding that petitioners failed to prove that Feliciano Catalan was insane or mentally incapacitated at the precise moment he executed the 1951 deed of donation?
- Are the Certificate of Disability for Discharge (Exhibit “S”) and the Board of Medical Officers’ reports (Exhibits “S‑1” and “S‑2”) admissible and sufficient to prove Feliciano’s incapacity at the time of the 1951 donation?
- Did the courts below err in upholding the March 26, 1979 Deed of Absolute Sale by Mercedes Catalan to Jesus and Delia Basa?
- Is Civil Case No. 17666 barred...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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