Gutierrez v. Mendoza-Plaza
REITERATIONFacts
The Antecedents: Ignacio Mendoza acquired a parcel of unregistered land in 1916. In 1940, Ignacio executed a deed of donation inter vivos donating the subject property to his children with his second wife, Ignacia. Ignacia accepted the donation on behalf of her children. Dominador and Victoria, children from Ignacio's first marriage, were instrumental witnesses to the deed. The deed was notarized but not registered. Respondents, Flora Mendoza-Plaza (daughter of Ignacio and Ignacia) and Ponciano Hernandez (son of Felisa, another daughter of Ignacio and Ignacia), alleged that after the donation, the property was assigned to Flora and Felisa, who possessed it. Ponciano took over after Felisa's death. In 2006, petitioners, heirs of Victoria (Ignacio's daughter from his first marriage), took possession of a portion of the property and constructed a house, prompting respondents to file a case for Accion Reivindicatoria, Publiciana, and Quieting of Title. Procedural History: Respondents filed a Complaint against petitioners in the Regional Trial Court (RTC) of Tanauan City. The RTC ruled in favor of respondents, declaring them lawful owners and ordering petitioners to demolish their house and vacate the premises. Petitioners appealed to the Court of Appeals (CA). The CA initially reversed the RTC decision, holding that the unregistered deed of donation was not valid against petitioners as third parties. However, upon respondents' Motion for Reconsideration, the CA issued an Amended Decision, recalling its initial ruling and affirming the RTC decision, finding that petitioners, as heirs of Ignacio, were bound by the donation. The Petition: Petitioners filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's Amended Decision. They argued that the deed of donation inter vivos was not authentic, was belatedly introduced, was fatally invalid due to non-registration, and substantively flawed as it impaired their legitimes. They also claimed ownership by prescription and laches due to their open, peaceful, and public possession.
Issue(s)
Whether the unregistered deed of donation inter vivos is valid and binding against the petitioners, who are heirs of the grantor's first marriage. Whether petitioners acquired ownership of the subject property by prescription or laches.
Ruling
The Supreme Court denied the petition, affirming the Court of Appeals' Amended Decision which upheld the Regional Trial Court's ruling in favor of the respondents. The Court declared respondents as the lawful owners of the subject property and ordered the petitioners to vacate and remove any structures they built thereon.
Ratio Decidendi
On Issue 1: The Supreme Court reiterated that while an unregistered deed of donation involving unregistered land is valid between the parties, it is not valid against third persons unless registered or unless such third persons have actual notice or knowledge thereof. However, the Court clarified that petitioners, as heirs of Ignacio Mendoza (the grantor), are considered extensions of the grantor and are therefore bound by the deed of donation inter vivos, even though it was unregistered. The Court emphasized that a notarized document enjoys a prima facie presumption of authenticity and due execution, which petitioners failed to overcome with clear and convincing evidence. The testimony of petitioner Elisa was deemed insufficient to impugn the deed. The Court also found no error in the deed being presented only after many years, as it was produced when petitioners asserted their claim of ownership. The non-registration of the deed does not affect its validity between the parties and its binding effect on heirs who have knowledge. On Issue 2: The Court found petitioners' claim of ownership by prescription to be without merit. Prescription requires possession in the concept of an owner, which must be public, peaceful, and uninterrupted. The Court found that the possession of the property by Victoria, and consequently by petitioners, was only by mere tolerance of Ignacio and later of the children from his second marriage (respondents). Article 1119 of the Civil Code states that acts of possessory character executed by mere tolerance of the owner do not constitute possession for purposes of prescription. Therefore, petitioners' possession, being by mere tolerance, could not ripen into ownership.
Main Doctrine
An unregistered deed of donation inter vivos involving unregistered land is valid between the donor and donee but is not valid against third persons unless registered or unless such third persons have actual notice or knowledge of the donation. Heirs of the donor, being considered extensions of the donor, are bound by the unregistered deed and cannot claim ownership by prescription against the donees.