Case Summary (G.R. No. 154942)
Factual Background
On January 16, 1978, Gregorio Santos donated the aforementioned lot to Rolando, which Rolando accepted on June 30, 1981. The deed of donation was duly annotated on Gregorio's title. Subsequently, on April 8, 1981, Gregorio executed a Deed of Absolute Sale of the same lot to Rolando. The property title was transferred from Gregorio’s name to Rolando’s on June 26, 1981, under a new title, TCT No. 144706. On January 11, 1991, Constancia filed a complaint in the Regional Trial Court of Manila, seeking partition and reconveyance of the property, arguing that the donation was inofficious as it impaired her legitime as a compulsory heir.
Legal Proceedings
The trial court ruled that the Deed of Absolute Sale was invalid due to the lack of signatures and registration, thus affirming the validity of the deed of donation. It found that as Gregorio possessed no other property, the donation was inofficious, depriving Constancia of her legitime. The court ordered the cancellation of the titles based on the donation and instructed both parties to initiate proper actions for the settlement of Gregorio's estate.
Court of Appeals Ruling
Upon appeal, the Court of Appeals sustained the trial court’s ruling, concluding that Gregorio did not sell the property but instead donated it to Rolando. It further emphasized that a donor is restricted from donating more than what can be freely disposed of by will, reinforcing the concept of inofficious donations. The appellate court noted that ownership through these documents was inconsistent with a legitimate sale, primarily due to the registration of the deed of donation.
Inofficious Donation Analysis
The decision highlighted that an inofficious donation occurs when the sum donated exceeds what one may dispose of freely by will, as outlined in Article 752 of the Civil Code. The courts found that Gregorio's sole property was the disputed lot, and since no reservations were made for Constancia’s legitime, his donation indeed constituted an inofficious act. Constancia’s entitlement to her legitime was affirmed to be one-half of the hereditary estate.
Prescription of Action Consideration
Rolando contended that Constancia’s action was barred by prescription since she was aware of the donation as early as 1978. However, the ruling clarified that the determination of inofficiousness can only occur posthumously. As a result, legal action concerning the reduction of an inofficious donation can be taken
...continue readingCase Syllabus (G.R. No. 154942)
Introduction
- This case revolves around a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, filed by Rolando Santos (petitioner) against Constancia Santos Alana (respondent).
- The petition seeks to challenge the Decision dated March 7, 2002, and the Resolution dated July 24, 2002, by the Court of Appeals in C.A.-G.R. CV No. 40728.
Factual Antecedents
- Rolando Santos and Constancia Santos Alana are half-blood siblings disputing ownership over a 39-square meter lot located at 1339-B Andalucia St., Sta. Cruz, Manila.
- The lot was registered under their deceased father, Gregorio Santos, in Transfer Certificate of Title (TCT) No. 14278.
- Gregorio Santos died intestate on March 10, 1986.
- On January 16, 1978, Gregorio donated the lot to Rolando, who accepted the donation on June 30, 1981. This donation was annotated on Gregorio's title.
- Subsequently, on April 8, 1981, Gregorio purportedly sold the lot to Rolando via a Deed of Absolute Sale.
- Following the donation, TCT No. 14278 was cancelled and TCT No. 144706 was issued in Rolando's name on June 26, 1981.
Procedural History
- On January 11, 1991, Constancia filed a complaint for partition and reconveyance in the Regional Trial Court of Manila, claiming that the donation was inofficious as it impaired her legitime.
- Rolando argued that Constancia's claim was barred by prescription, as he had been in possession of the lot for over ten years.
- The