Case Digest (G.R. No. L-67888)
Facts:
Imelda Ong, et al. v. Alfredo Ong, et al., G.R. No. 67888, October 08, 1985, First Division, Relova, J., writing for the Court. On February 25, 1976 petitioner Imelda Ong executed a Quitclaim Deed in favor of private respondent Sandra Maruzzo, then a minor, conveying "one-half (1/2) undivided portion" of a described parcel in Makati "for and in consideration of One (P1.00) Peso and other valuable considerations." On November 19, 1980 Imelda purported to revoke that Quitclaim Deed and, on January 20, 1982, she executed a Deed of Donation conveying the whole property to her son, Rex Ong Jimenez.On June 20, 1983 Sandra Maruzzo, through her guardian ad litem Alfredo Ong, filed suit in the Regional Trial Court (RTC), Makati, for recovery of ownership/possession and for nullification of the subsequent Deed of Donation insofar as it affected her half interest, and for accounting. Petitioners contended the Quitclaim Deed was in effect a donation requiring acceptance and was void because the donee was a minor incapable of accepting; they also attacked the sufficiency of the P1.00 recited consideration.
The RTC rendered judgment on December 12, 1983 in favor of Sandra Maruzzo, holding the Quitclaim Deed equivalent to a deed of sale and effecting a valid conveyance. Petitioners appealed to the Intermediate Appellate Court (IAC), which on June 20, 1984 in AC-G.R. No. CV-01748 affirmed the RTC, reasoning that the deed recited a consideration (P1.00 and other valuable considerations), that the nominal amount was a common practice, and that the presumption of sufficient cause and the absence of conditions made guardian acceptance unnecessary for a minor beneficiary.
Petitioners filed a petition for review on certiorari to the Supreme Court attacking the IAC's interpretation of the Quitclaim Deed. During the Supreme Court proceedings, Sandra Maruzzo informed the Court that she had attai...(Subscriber-Only)
Issues:
- Whether the Quitclaim Deed executed by Imelda Ong conveyed ownership to Sandra Maruzzo or was void as a donation not validly accepted by a minor.
- Whether the recited consideration of One (P1.00) Peso suffices to sustain the Quitclaim Deed as a valid conveyance.
- Whether acceptance by a legal representative (guardian) was required to validate a donation in favor o...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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