Case Summary (G.R. No. L-58671)
Background of the Case
- Eduvigis J. Cruz, a childless widow, donated a 235.5 square meter residential lot in San Isidro, Taytay, Rizal, along with a two-door apartment, to her grandnieces, Teresita, Lydia, and Cecilia De Leon, in 1973.
- The donation was formalized through a deed entitled "Kasulatan Sa Kaloobpala," and the property was subsequently transferred to the names of the donees.
- In 1974, Eduvigis Cruz adopted a minor named Cresencia Ocreto and later attempted to extrajudicially revoke the donation, which the donees contested.
Arguments of the Donees
- The donees claimed that the property was co-owned by Eduvigis and her deceased brother, Maximo Cruz, which entitled them to inherit half of the property.
- They also argued that Eduvigis owned another agricultural property exceeding two hectares, asserting that the donation did not impair the presumptive legitime of the adopted child.
Trial Court Proceedings
- In 1975, Eduvigis filed a complaint for revocation of the donation in the Court of First Instance of Rizal, citing Article 760, paragraph 3 of the New Civil Code, which allows for revocation upon the adoption of a minor child.
- The trial court ruled in favor of Eduvigis, revoking the donation based on the acceptance of the deed by the donees and dismissing their claims regarding co-ownership and legitime impairment.
Court of Appeals Decision
- The Court of Appeals reversed the trial court's decision, emphasizing that it had only considered Article 760 and ignored Article 761, which pertains to the limits of donation revocation based on the donor's estate.
- The appellate court noted that Eduvigis owned another lot valued at P273,420.00, and that the donated lot was co-owned, thus reducing the value of the donation within the free portion of her estate.
- The court concluded that the burden of proof lay with Eduvigis to demonstrate that the donation impaired the legitime of the adopted child, which she failed to do.
Legal Principles and Burden of Proof
- The decision highlighted that a donor who adopts a minor can seek annulment or reduction of prior donations within four years if such donations impair the legitime of the adopted child, as per Articles 760, 761, and 763 of the Civil Code.
- The burden of proof rests on the donor to establish that the donation impairs the legitime, which Eduvigis did not adequ...continue reading