Title
Ong vs. Ong
Case
G.R. No. L-67888
Decision Date
Oct 8, 1985
Imelda Ong executed a Quitclaim Deed transferring land to minor Sandra Maruzzo for P1.00. After revocation and donation to her son, Sandra sued. Courts upheld the deed as valid conveyance, not a donation, with sufficient consideration.
valid conveyance
nominal consideration
valuable consideration
A

Case Summary (G.R. No. L-67888)

Factual Background

On February 25, 1976, Imelda Ong executed a Quitclaim Deed in favor of Sandra Maruzzo, then a minor, conveying her rights, title, interest and participation in one-half of a described parcel of land for and in consideration of One (P1.00) Peso and "other valuable considerations." On November 19, 1980, Imelda Ong revoked the Quitclaim Deed. On January 20, 1982, she executed a Deed of Donation of the whole described property in favor of her son, Rex Ong Jimenez. On June 20, 1983, Sandra Maruzzo, through her guardian ad litem Alfredo Ong, filed an action in the Regional Trial Court of Makati for recovery of ownership and possession, nullification of the Deed of Donation insofar as it affected her portion, and for accounting.

Trial Court Proceedings

In the trial court, petitioners asserted that the Quitclaim Deed was equivalent to a Deed of Donation and therefore required acceptance by the donee to be valid; they further argued that the minor donee lacked legal personality to accept the donation. After the parties admitted the documents, filed memoranda and submitted the case for decision, the Regional Trial Court rendered judgment on December 12, 1983 in favor of respondent Maruzzo, holding that the Quitclaim Deed was equivalent to a Deed of Sale and constituted a valid conveyance in favor of the donee.

Intermediate Appellate Court Ruling

On June 20, 1984, the Intermediate Appellate Court affirmed the trial court. The Appellate Court held that the Quitclaim Deed effected a conveyance with a valid cause or consideration, that the stated consideration included the One (P1.00) Peso and the "other valuable considerations," and that the nominalness of the stated monetary consideration did not defeat the validity of the conveyance. The Appellate Court invoked the presumption that a cause exists where the contract so states (Article 1354, Civil Code), and cited Section 5(r), Rule 131, Rules of Court, together with precedents holding that execution of a deed conveying realty is prima facie evidence of valuable consideration (Samanilla v. Cajucom, Caballero v. Caballero). The Appellate Court further held that, even if the instrument were characterized as a donation, the requirement of acceptance by parents or legal representatives applied only to onerous and conditional donations (Article 726, Civil Code), whereas simple or pure donations did not require formal acceptance by a guardian (Article 741, Civil Code), and it cited Perez v. Calingo and Kapunan v. Casilan to that effect.

Parties' Contentions on Certiorari

In this petition for review on certiorari, petitioners challenged the Intermediate Appellate Court's interpretation of the Quitclaim Deed and again contended that the instrument was in substance a donation that required acceptance and thus was void as to a minor who could not lawfully accept. Petitioners also challenged the sufficiency of the One (P1.00) Peso recited as consideration, labeling it nominal and asserting that it did not sustain a finding of a conveyance for value. Respondent Sandra Maruzzo informed the Supreme Court that she had attained majority and moved to be substituted for her guardian ad litem; the Supreme Court granted the substitution.

Supreme Court Ruling

The Supreme Court affirmed the decision of the Intermediate Appellate Court and ordered costs against the petitioners. The Court held that the Quitclaim Deed expressly recited consideration consisting of One (P1.00) Peso and "other valuable considerations," and that the cause or consideration therefore was not limited to the nominal peso alone. The Court applied Article 1354, Civil Code, and the presumption that a contract has a sufficient cause when the instrument itself states that consideration was given. The Court held that the presumption of consideration, and the prima facie effect of a public instrument purporting to convey realty, could not be overcome by mere assertion; the party alleging lack of consideration bore the burden of proving that allegation by a preponderance of evidence. The Court also reiterated that inadequacy of consideration or a nominal recited amount did not render a conveyance inexistent, and that bad faith or fraud, when proven, rendered a contract rescissible or voidable but not void ab initio. Finally, the Court agreed with the Appellate Court that acceptance by a guardian was unnecessary for a simple or pure donation that imposed no condition or burden on the donee, citing Article 726 and Article 741 of the Civil Code and the authorities relied upon below.

Legal Basis and Reasoning

The Court anchored its conclusion on the legal presumption that a contract contains a sufficient cause when it recites consideration (Article 1354), and on the procedural presumption embodied in Section 5(r), Rule 131, Rules of Court. The Court emphasized the evidentiary effect of a public deed conveying real estate as prima facie proof of valuable consideration, placing the burden on the party who asserts lack of consideration to prove that claim by a preponderance of evidence, as in

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms