Case Digest (G.R. No. L-2548) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Dr. Mariano Favis, Sr. (G.R. No. 185922, January 15, 2014), petitioners are the seven legitimate children of the late Dr. Mariano Favis, Sr. by his first wife, Capitolina Aguilar. After Capitolina’s death in 1944, Dr. Favis entered a common-law union with Juana Gonzales, formally marrying her in 1974 and legitimating their son, Mariano G. Favis. Between 1992 and his death in 1995 at age 92, Dr. Favis suffered from serious illnesses, including hiatal hernia, Parkinson’s disease, congestive heart failure, and pneumonia. On October 16, 1994, he executed a Deed of Donation transferring his residential lot and commercial building in Vigan, Ilocos Sur, to his grandchildren by Juana. Believing this donation prejudiced their legitime, the seven children from the first marriage filed in the Regional Trial Court (RTC) an action for annulment of donation, inventory, liquidation, and partition. The RTC limited issues to the donation’s validity and the heirship status of Juana an Case Digest (G.R. No. L-2548) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationships
- Dr. Mariano Favis, Sr. (decedent) first married Capitolina Aguilar and had seven children: Purita, Reynaldo, Consolacion, Mariano Jr., Esther, Mercedes, and Nelly.
- After Capitolina’s death (1944), Dr. Favis lived with Juana Gonzales as common-law wife, siring Mariano G. Favis; they married in 1974, legitimating Mariano.
- Mariano G. Favis married Larcelita D. Favis; they had four children (Ma. Theresa Joana, Ma. Cristina, James Mark, Ma. Thea).
- Estate and Deed of Donation
- At death (29 July 1995), Dr. Favis owned five properties in Vigan, Ilocos Sur (two residential lots, a commercial building, a house, an orchard lot).
- On 16 October 1994, at age 92 and after years of illness (hiatal hernia, Parkinson’s, pneumonia), he executed a Deed of Donation conveying the Bonifacio St. parcel and commercial building to his grandchildren by Juana.
- Procedural History
- Petitioners (first-family heirs) filed before RTC for annulment of the Deed of Donation, inventory, liquidation, and partition, alleging prejudice to their legitime; respondents contended the donation was inter vivos and excluded from the estate.
- RTC (14 Nov 2005) nullified the Deed of Donation for vitiated consent, held Juana and Mariano as compulsory heirs, and decreed intestate distribution among all compulsory heirs.
- Respondents appealed to CA, which, motu proprio, dismissed the annulment complaint for failure to allege earnest compromise efforts as required by Article 151, Family Code.
- Petitioners moved for reconsideration in CA and then elevated the case to the Supreme Court, also challenging the substantive nullification ruling.
Issues:
- Whether the Court of Appeals erred in motu proprio dismissing the petitioners’ annulment complaint for failure to allege earnest efforts at compromise under Article 151 of the Family Code.
- Whether the Deed of Donation is void for lack of valid consent, given the donor’s advanced age and debilitating illnesses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)