G.R. No. 154942 - Santos vs. Alana

Rolando Santos (petitioner) and Constancia Santos Alana (respondent) are half-blood siblings.
The dispute involves a 39-square meter lot located at 1339-B Andalucia St., Sta. Cruz, Manila, originally registered in the name of their father, Gregorio Santos, under TCT No. 14278.
Gregorio Santos died intestate on March 10, 1986, leaving the lot as his only property.

During his lifetime or on January 16, 1978, Gregorio Santos donated the lot to Rolando Santos; the deed of donation (Pagsasalin ng Karapatan at Pag-aari) was duly executed and later annotated on the original title.
Subsequently, on April 8, 1981, a Deed of Absolute Sale purportedly transferring the lot to Rolando Santos was executed; however, this transaction was disputed later.
The deed of donation was given effect when on June 26, 1981, TCT No. 14278 was cancelled and replaced by TCT No. 144706 in the name of the petitioner, following the annotation of the donation.

On January 11, 1991, Constancia Santos Alana filed a complaint for partition and reconveyance before the Regional Trial Court of Manila, alleging:

That their father, Gregorio Santos, had denied selling the lot to Rolando and instead donated it during his lifetime.
That the donation was inofficious as it impaired her legitime, being deprived of her rightful share as a compulsory heir.

That the suit was barred by prescription given his prolonged possession as owner of the lot for over ten years.
That the lot was acquired by sale from his father, and thus Constancia could not claim her legitime.

The Deed of Absolute Sale was invalid as it was neither signed by the required parties nor registered with the Registry of Deeds, rendering it void as a contract.
The valid deed was the donation, having been duly executed and registered.
Since the lot was the only property of Gregorio Santos, the donation was inofficious because it impaired the legitime of Constancia Santos Alana.
The court ordered cancellation of the donation’s entry on the title and enjoined the parties to pursue proper estate settlement and partition proceedings.

That the deed of donation was valid as evidenced by its proper registration.
The absence of a valid deed of sale; the true transaction was a donation.
The legal basis that no person may donate more than what he could dispose of by will, thereby rendering donations inofficious if they exceed that share.

Rolando Santos argued that since Constancia had knowledge of the donation since 1978, her claim filed in 1991 was time-barred by prescription.
The courts clarified that the prescriptive period for reducing inofficious donations should be calculated from the death of the donor (1986) and noted that Constancia’s suit, filed in 1992, was within the ten-year period provided under Article 1144 of the Civil Code.

Whether the donation executed by Gregorio Santos to Rolando Santos is inofficious by virtue of exceeding the donor’s permissible limit (i.e., more than he may give or receive by will).
Whether Constancia Santos Alana’s action for partition and reconveyance is barred by prescription.