Case Digest (G.R. No. L-22005)
Facts:
Jesusa Lacson Vda. de Arroyo, et al. v. El Beaterio del Santissimo Rosario de Molo, et al., G.R. No. L-22005, May 03, 1968, the Supreme Court En Banc, Dizon, J., writing for the Court. Petitioners are the heirs of Jose Arroyo (led by Jesusa Lacson Vda. de Arroyo); respondents include El Beaterio del Santissimo Rosario de Molo (a religious corporation) and other heirs/parties connected to the Arroyo family.The contested facts begin in 1924 when Ignacio Arroyo executed a public instrument entitled “Convenio de Reparticion de Bienes y Adjudicacion de Herencia” partitioning his estate among his three children (Jose Arroyo, Mariano Arroyo and Sor Rosario de la Visitacion) and reserving a one‑third portion to himself. Jose Arroyo died in 1927; in 1928 Ignacio Arroyo executed an “Escritura de Donacion” conveying most of the properties adjudicated to him to the Beaterio, which the donee accepted; subsequent instruments in 1931 clarified and modified the donation’s terms. Ignacio Arroyo’s 1931 will reproduced the convenio and narrated the donation; he died on January 8, 1935, and his will was probated on February 25, 1935.
In 1936 Ricardo Carreon, as administrator of Concepcion Gerona’s estate, filed suit (Civ. Case No. 9137, CFI Iloilo) seeking recovery of portions of the properties; that case was tried, its records were later destroyed by war, and on retrial the plaintiffs eventually compromised in 1949 with Jesusa Lacson (administrator of Jose Arroyo’s estate), who received P65,000 and attorneys’ fees, after which the CFI dismissed the complaint.
On March 13, 1958 petitioners (Jesusa and her children, heirs of Jose Arroyo) filed the present complaint in CFI Iloilo (Civil Case No. 4759) asking that Ignacio Arroyo’s 1928 donation to the Beaterio be declared inofficious and that the excess be recovered. The Beaterio answered and counterclaimed. After trial the CFI rendered judgment on August 29, 1960 dismissing the complaint and the counterclaim, holding that petitioners failed to establish a fair and reliable basis to declare the donation inofficious.
The Court of Appeals (C.A.-G.R.-28555) affirmed the CFI decision, concluding there was no fair and reasona...(Pro-only)
Issues:
- Procedural: May the Supreme Court reverse the Court of Appeals’ factual finding that the donation was not shown to be inofficious, or is that finding conclusive absent an error of law?
- Substantive: Was the 1928 donation by Ignacio Arroyo to the Beaterio proved to be inofficious such that the excess should be r...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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