Case Digest (G.R. No. 224307)
Facts:
In The Missionary Sisters of Our Lady of Fatima (Peach Sisters of Laguna), represented by Rev. Mother Ma. Concepcion R. Realon, et al. v. Amando V. Alzona, et al. (G.R. No. 224307, decided May 6, 2019), the petitioner is a religious and charitable group organized under the Roman Catholic Bishop of San Pablo on May 30, 1989, and subsequently incorporated under a Certificate of SEC registration dated August 31, 2001. Its Superior General, Mother Ma. Concepcion R. Realon, accepted a Deed of Donation Inter Vivos executed on August 29, 2001 by Purificacion Y. Alzona, a spinster suffering from lung cancer and registered owner of several parcels of land in Calamba City, Laguna (TCT Nos. T-57820, T-162375, and undivided share in TCT No. T-162380). Purificacion first signified her intent to give her house and rice land to the petitioner via a handwritten letter in October 1999 and later formalized it in a public deed before Atty. Nonato Arcillas, with acceptance by Mother Concepcion on tCase Digest (G.R. No. 224307)
Facts:
- Parties and Background
- Petitioners
- Missionary Sisters of Our Lady of Fatima (Peach Sisters of Laguna), a religious-charitable group under the Roman Catholic Bishop of San Pablo.
- Superior General: Rev. Mother Ma. Concepcion R. Realon.
- SEC Certificate of Incorporation issued August 31, 2001.
- Respondents
- Legal heirs of the late Purificacion Y. Alzona (donor).
- Initially represented by her brother Amando Y. Alzona (now succeeded by his heirs).
- Antecedent Facts
- Purificacion owned two parcels (TCT Nos. T-57820* and T-162375) and co-owned another (TCT No. T-162380) in Calamba City, Laguna.
- In 1996, she supported the petitioner’s mission; in 1997, diagnosed with lung cancer and entrusted her care to Mother Concepcion.
- October 1999 handwritten letter: Purificacion declared her intent to donate her house and lot and riceland to the petitioner.
- August 28, 2001: petitioner filed SEC registration upon advice of Atty. Nonato Arcillas.
- August 29, 2001: Purificacion executed a notarized Deed of Donation Inter Vivos transferring the three properties to the petitioner, accepted by Mother Concepcion on the same date.
- January 14, 2002: BIR granted donor’s tax exemption to the petitioner.
- Register of Deeds refused registration due to an Affidavit of Adverse Claim by Amando Alzona.
- October 30, 2001: Purificacion died intestate; Amando filed suit April 9, 2002 to annul the deed, alleging the petitioner lacked juridical personality at donation time.
- August 14, 2013: RTC dismissed the complaint, held petitioner a de facto corporation capable of accepting donation.
- January 7, 2016: CA partly granted respondents’ appeal, voided the deed for lack of petitioner’s juridical personality; denied damages.
- April 19, 2016: CA denied petitioners’ motion for reconsideration.
- Petitioners elevated the case to the Supreme Court via Rule 45 petition for certiorari.
Issues:
- Whether the Deed of Donation by Purificacion in favor of the petitioner is valid and binding.
- Whether the petitioner, as donee, had legal capacity (juridical personality) at the time of donation.
- Whether Mother Ma. Concepcion R. Realon had authority to accept the donation on behalf of the petitioner.
- Whether doctrines of de facto corporation, corporation by estoppel, ratification, and privity in estate apply to uphold the donation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)