G.R. No. 206673 - 1st Philippine Holdings Corp. vs. Securities and Exchange Commission

1944: Herminigildo and Raymunda Locquiao executed an Inventario Ti Sagut (donation propter nuptias) in Ilocano, granting several parcels (including the land in question), a male cow, and one-third of their conjugal house to their son Benito and his bride-to-be Tomasa. The donees married June 4, 1944, and this was annotated on O.C.T. No. 18383.
1962–1968: Donor-spouses died, leaving six heirs (including Benito and Romana). Romana cultivated the subject land with respondents’ permission; Constancia succeeded her in 1977.
1970–1973: The donation was registered May 15, 1970; O.C.T. No. 18383 was canceled and TCT No. 84897 issued to Benito and Tomasa. A 1973 Deed of Partition distributed twelve parcels among heirs but excluded those previously donated; a 1976 Deed of Compromise redistributed two other lots, reaffirming the 1973 partition.

1983: Constancia filed an annulment of title (dismissed by the RTC). Benito filed ejectment against her; the MTC ordered her ouster in 1985.
1985: Romana and Constancia sued to annul TCT No. 84897, alleging fraud, spurious document, notarial defect, and lack of formal acceptance of the donation. The RTC consolidated the ejectment and annulment cases, then in January 1989 dismissed the annulment for prescription and laches, upheld the donation’s validity, and affirmed the ejectment.
1994–1995: The Court of Appeals affirmed both RTC decisions and denied reconsideration.
2003: The Supreme Court granted review.

The Inventario Ti Sagut is a duly notarized public instrument; absence of a notarial record in archives does not prove forgery.
Subsequent deeds of partition and compromise reference and confirm the prior donation propter nuptias.
As a public document, it is conclusive of its contents unless overturned by clear and convincing evidence.

Under the Old Civil Code (in force in 1944), donations propter nuptias must be in a public instrument but require no acceptance (Art. 1330).
Implied acceptance arises from the donees’ marriage and its annotation on the title.
Petitioners incorrectly applied the requirements for ordinary donations instead of those for donations propter nuptias.

Cause of action for reconveyance accrued in 1944; Act No. 190 prescribes a 10-year period for actions to recover title or possession of real property (Sec. 40).
Petitioners’ 1985 complaint was filed over 40 years after accrual and more than 15 years after TCT

The subject is a 4,876-sqm parcel in Urdaneta, Pangasinan, originally registered as O.C.T. No. 18383 (October 3, 1917) in the names of spouses Herminigildo and Raymunda Locquiao.
On May 22, 1944, the spouses executed an Ilocano deed of donation propter nuptias (“Inventario Ti Sagut”) in favor of their son Benito Locquiao and fiancée Tomasa Mara, gifting four parcels (including the subject land), a cow, and one-third of the conjugal house, in consideration of their impending marriage.
Benito and Tomasa married on June 4, 1944; the marriage was annotated at the back of OCT No. 18383.
The donors died in 1962 and 1968, leaving six heirs: Benito, Marciano, Lucio, Emeteria, Anastacia, and Romana.
With Benito and Tomasa’s permission, Romana Valencia occupied and cultivated the land; in 1977, her daughter Constancia Valencia assumed possession.
On May 15, 1970, the Inventario Ti Sagut was registered; O.C.T. No. 18383 was cancelled and TCT No. 84897 was issued in the names of Benito and Tomasa.
On March 18, 1973, the heirs (including Romana and Benito) executed a Deed of Partition with Recognition of Rights, distributing 12 parcels among three heirs and expressly confirming prior donations; the subject land was excluded.
On June 12, 1976, five heirs executed a Deed of Compromise to redistribute two lots; Benito signed and all signatories reconfirmed the partition’s stipulations.

1983: Constancia filed an action for annulment of title (Agrarian Case No. 1406) in RTC Pangasinan; the case was dismissed (reason not indicated).
December 13, 1983: Benito sought ejectment of Constancia in MTC Urdaneta; November 25, 1985: MTC ordered Constancia to vacate.
December 23, 1985: Romana and Constancia filed in RTC Pangasinan a complaint to annul TCT No. 84897, alleging fraud, spurious Inventario Ti Sagut, unauthorized notarization, and lack of acceptance.
RTC suspended the ejectment pending resolution of the title annulment.
January 30, 1989: RTC dismissed the annulment complaint on grounds of prescription and laches; upheld validity of the donation propter nuptias; affirmed the MTC ejectment decision.
November 24, 1994: Court of Appeals (Tenth Di