Tabar v. Becada
REITERATIONFacts
1. The Antecedents: Feliciano Becada and his wife Placida Endab resided in Dumanjug, Cebu, and employed Serapio Tabar and his wife as tenants. The Becadas acted as godparents to the Tabars' daughter, Urbana, and subsequently took her into their home when she was about one year old. Urbana remained with the Becadas for approximately nine years, during which time her parents performed minimal parental duties, while the Becadas provided for her welfare. In 1910, the Tabars moved away due to local unrest but left Urbana with the Becadas. Two years later, Serapio Tabar sought Urbana's return, potentially motivated by her approaching age of majority and the local custom of bugay (dowry) upon marriage. 2. Procedural History: Following Urbana's marriage to Timoteo Romero in 1916 and their subsequent departure from the Becadas' residence in 1918, Serapio Tabar, Urbana Tabar, and Timoteo Romero initiated an action in the Court of First Instance of Cebu. They sought to validate a document, purportedly signed by the Becadas in 1912, which stipulated that Urbana would receive one-half of the Becadas' property upon marriage or if she left their care, or if the Becadas died. The Becadas contested the validity of this document, arguing it was fictitious. The trial court, however, found the document to be valid and rendered a judgment in favor of the plaintiffs, ordering the Becadas to deliver one-half of their property. 3. The Petition: The defendants-appellants, Feliciano Becada and Placida Endab, appealed the decision of the Court of First Instance to the Supreme Court. Their primary contention revolved around the authenticity and validity of the document presented as Exhibit A, which they alleged was never truly made. The Supreme Court, however, affirmed the lower court's judgment. The Court found the document to be in the nature of a donation con causa onerosa, governed by the Civil Code provisions on contracts. It concluded that Urbana Tabar's actions demonstrated her acceptance of the contract's stipulations, and thus, there was no legal impediment to enforcing its terms. The appeal was dismissed, with costs against the appellants.
Issue(s)
Whether the document Exhibit A, in the nature of a donation con causa onerosa, is valid and binding. Whether Urbana Tabar, as a minor, could accept the stipulations of the contract.
Ruling
The judgment of the Court of First Instance is affirmed, with costs against the appellants.
Ratio Decidendi
On the validity and binding nature of the document Exhibit A: The Court affirmed the trial court's finding that the document Exhibit A was not fictitious. The testimony of witnesses, including Pio Samson who drafted the instrument, Claudio Tacoloy who signed as a witness, and the justice of the peace, Vicente Segovia, all supported the trial court's conclusion. The document was characterized as a donation con causa onerosa, which is governed by the provisions of the Civil Code relating to contracts. The Court found no legal impediment to giving effect to this contract. On the acceptance of the contract by Urbana Tabar: The Court held that all the acts of Urbana Tabar led to the conclusion that she accepted the stipulations of the contract. Despite her minority, her continued residence with the Becadas, her marriage with the permission of the Becadas, and the bugay being offered and accepted by them, demonstrated her acceptance. The Court cited Articles 621 and 622 of the Civil Code, as well as previous jurisprudence, to support the principle that acceptance of a donation, even by a minor, can be inferred from conduct. The Court found no obstacle in Article 1257 of the Civil Code, as argued by the appellants, because Urbana's actions clearly indicated her acceptance of the contract's terms.
Main Doctrine
A document in the nature of a donation con causa onerosa, which is governed by the provisions of the Civil Code relating to contracts, will be given effect if the stipulations are accepted, even if it involves a minor, provided the acceptance is evident from the minor's actions.