Case Digest (G.R. No. L-15939)
Facts:
- The case involves plaintiffs Angeles Ubalde Puig and others against defendants Estela Magbanua Penaflorida and others.
- The Supreme Court of the Philippines rendered its decision on November 29, 1965.
- The case originated from a March 23, 1959 decision by the Court of First Instance of Iloilo in Civil Case No. 2892.
- The lower court declared certain deeds of donation executed by Carmen Ubalde Vda. de Parcon as null and void.
- Carmen Ubalde passed away on April 10, 1953, in Iloilo City, leaving properties and a will.
- She was survived by her nephew and nieces, children of her deceased brother Catalmo Ubalde and sister Luisa Ubalde, who was married to Ariston Magbanua.
- Carmen executed two notarial deeds of donation:
- The first, dated November 24, 1948, was a "donacion mortis causa" to her niece Estela Magbanua, covering properties with specific stipulations.
- The second, dated December 28, 1949, also labeled "donacion mortis causa," conveyed additional properties to Estela under similar conditions.
- Both deeds were recorded after Carmen's death.
- The executor and special administrator, Mariano B. Penaflorida, did not contest the validity of the donations.
- Carmen's nephews and nieces filed a suit to annul the donations for lack of testamentary formalities.
- The Court of First Instance ruled the donations invalid and ordered the return of properties to the estate for lawful distribution.
- Both parties appealed the decision.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that:
- The donation dated November 24, 1948, is valid as a donation inter vivos.
- The donation dated December 28, 1949, is a mortis causa conveyance and is invalid due to lack of testamentary formalities.
- The Court affirmed th...(Unlock)
Ratio:
- The Supreme Court's decision focused on the nature of the donations.
- The Court noted that the concept of "donation mortis causa" was removed from Philippine law with the enactment of the Civil Code, which recognizes only inter vivos donations and testamentary dispositions.
- The first deed, despite being labeled mortis causa, was considered inter vivos due to stipulations indicating an immediate transfer of rights and obligations, including the donee's responsibility for the donor's medical and burial expenses.
- The...continue reading
Case Digest (G.R. No. L-15939)
Facts:
The case involves Angeles Ubalde Puig and others as plaintiffs and Estela Magbanua Penaflorida and others as defendants, with the decision rendered on November 29, 1965, by the Supreme Court of the Philippines. The case originated from a decision made on March 23, 1959, by the Court of First Instance of Iloilo in Civil Case No. 2892, which declared certain deeds of donation executed by Carmen Ubalde Vda. de Parcon as null and void. Carmen Ubalde passed away on April 10, 1953, in the City of Iloilo, leaving behind properties and a will. She was survived by her nephew and nieces, who were the children of her deceased brother, Catalmo Ubalde, and sister, Luisa Ubalde, who was married to Ariston Magbanua.
Carmen Ubalde had executed two notarial deeds of donation. The first, dated November 24, 1948, was a "donacion mortis causa" in favor of her niece, Estela Magbanua, conveying properties covered by Transfer Certificates of Title Nos. 2338 and 18951, with stipulations regarding the donor's rights to mortgage or sell the properties and the donee's obligations to cover medical and burial expenses. The second deed, dated December 28, 1949, also labeled as "donacion mortis causa," conveyed additional properties to Estela Magbanua under similar conditions. Both deeds were recorded after Carmen's death.
Following the submission of her will to the court, the executor and special administrator, Mariano B. Penaflorida, did not contest the validity of the donations. Consequently, the nephews and nieces of Carmen Ubalde filed a suit against their cousins, seeking to annul the donations for lack of testamentary...