Valencia v. Locquiao
REITERATIONFacts
The Antecedents: This case concerns a parcel of land originally owned by spouses Herminigildo and Raymunda Locquiao. On May 22, 1944, they executed a deed of donation propter nuptias, the Inventario Ti Sagut, in Ilocano, gifting four parcels of land, including the subject property, a cow, and a portion of their house to their son, respondent Benito Locquiao, and his prospective bride, respondent Tomasa Mara, in consideration of their impending marriage. The couple married on June 4, 1944. Herminigildo and Raymunda Locquiao died in 1962 and 1968, respectively, leaving six children, including respondent Benito and petitioner Romana. With permission, petitioner Romana took possession of the land, and later, her daughter, petitioner Constancia, took over possession. Meanwhile, respondents Benito and Tomasa registered the donation, leading to the cancellation of the original title and the issuance of Transfer Certificate of Title No. 84897 in their names. Procedural History: In 1983, petitioner Constancia filed an action for annulment of title, which was dismissed by the Regional Trial Court (RTC). Subsequently, on December 13, 1983, respondent Benito filed an ejectment case against petitioner Constancia, resulting in a Municipal Trial Court (MTC) decision ordering her to vacate the land. Petitioners Romana and Constancia then filed a complaint for annulment of Transfer Certificate of Title No. 84897, alleging fraud in its issuance and the spuriousness of the Inventario Ti Sagut. The RTC consolidated the ejectment case appeal with the annulment of title case. On January 30, 1989, the RTC dismissed the annulment complaint, ruling that the action was barred by prescription and laches, and affirmed the MTC's decision in the ejectment case. The Court of Appeals (CA) affirmed the RTC's decisions on November 24, 1994, and denied the motion for reconsideration on September 8, 1995. This led to the present petition. The Petition: Petitioners seek review of the Court of Appeals' decision affirming the dismissal of their action for annulment of title and the affirmation of the ejectment order. They argue that the Inventario Ti Sagut is not authentic and that the donation propter nuptias is void for lack of proper acceptance. They also contend that their action is not barred by prescription or laches. The Supreme Court is asked to determine the authenticity of the donation, the necessity and form of acceptance for donations propter nuptias, and whether the action is barred by prescription and laches. The Court must also address the factual issues raised in the ejectment case.
Issue(s)
Whether the Inventario Ti Sagut is authentic. Whether acceptance of the donation by the donees is required, and if so, in what form should it appear. Whether the action for annulment of title is barred by prescription and laches. Whether the issues raised in the ejectment case are factual and beyond the Court's power of review.
Ruling
The petition is devoid of merit. The assailed decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the authenticity of the Inventario Ti Sagut: The Court found that the certification from the Records Management and Archives Office regarding the absence of a notarial record for the notary public who notarized the Inventario Ti Sagut was insufficient to prove the document's spuriousness. The Court reiterated its ruling that the failure of a notary public to furnish a copy of a deed to the appropriate office is a ground for disciplinary action against the notary but does not invalidate the document itself. Furthermore, the Deed of Partition with Recognition of Rights and the Deed of Compromise Agreement, executed by the heirs including petitioner Romana, implicitly recognized prior donations, and respondent Benito was not allotted a share in the partition precisely because he had already received his share through previous donations, thereby dispelling doubts about the authenticity of the Inventario Ti Sagut. On the requirement and form of acceptance for donation propter nuptias: The Court clarified that the petitioners, the appellate court, and the trial court erred in applying the rules for ordinary donations to donations propter nuptias. Under the Old Civil Code, which is applicable as the donation was executed in 1944, Article 1330 explicitly provides that acceptance is not necessary for the validity of donations propter nuptias. The celebration of the marriage between the donees, coupled with compliance with the prescribed form (a public instrument describing the property), was sufficient to effectuate the donation. Therefore, the absence of a formal written acceptance did not invalidate the donation. On prescription and laches: The Court held that the action for annulment of title was barred by prescription. Under Act No. 190 (Old Code of Civil Procedure), the ten-year prescriptive period for actions to recover title or possession of real property applies. The cause of action accrued in 1944 when the Inventario Ti Sagut was executed. Even if the prescriptive period were to commence from the discovery of alleged fraud, the registration of the deed and issuance of the TCT on May 15, 1970, constituted constructive notice to the petitioners, making their action filed on December 23, 1985, time-barred. Furthermore, the action was dismissible on the ground of laches, as petitioner Romana had knowledge of the donation as early as 1973 and 1976 when the deeds of partition and compromise were executed, yet she delayed in asserting her rights until 1985, causing prejudice to the respondents. On the ejectment case: The Court found the issues raised in the ejectment case to be factual and beyond its power of review, noting that it is not a trier of facts. The affirmance of the CA decision implicitly meant that there was substantial evidence supporting the lower courts' findings.
Main Doctrine
Under the Old Civil Code, acceptance is not necessary for the validity of a donation propter nuptias; the celebration of the marriage between the beneficiary couple, coupled with compliance with the prescribed form, is sufficient to effectuate the donation. Furthermore, actions for reconveyance of real property are subject to a ten-year prescriptive period under Act No. 190, commencing from the accrual of the cause of action or from the registration of the deed which constitutes constructive notice.