The Supreme Court held that a donation propter nuptias (by reason of marriage) of real property, made through a private instrument before the effectivity of the New Civil Code on August 30, 1950, is void. This means that such a donation does not effectively transfer ownership of the property. The Court emphasized that under the Old Civil Code, such donations must be made in a public instrument to be valid. This ruling clarifies the formal requirements for donations of real property made before the enactment of the New Civil Code, protecting property rights and ensuring compliance with established legal procedures. The decision underscores the importance of adhering to the specific legal requirements in place at the time of the transaction.

Unraveling a Century-Old Dowry: Did a Private Deed Secure Land Ownership?

This case revolves around a parcel of land in Asingan, Pangasinan, originally owned by spouses Simeon Doronio and Cornelia Gante, covered by Original Certificate of Title (OCT) No. 352. Marcelino Doronio and Fortunato Doronio, both children of the spouses, are the predecessors of the parties in this case. The dispute arose from a private deed of donation propter nuptias executed in 1919 by Simeon and Cornelia in favor of Marcelino and his wife, Veronica Pico. The heirs of Marcelino (petitioners) claim ownership of the entire property based on this deed. Conversely, the heirs of Fortunato (respondents) contend that only half of the property was intended for donation, pointing to discrepancies in the property’s description in the OCT and the deed. The central legal question is whether the private deed of donation validly transferred ownership of the real property, considering the legal requirements in place at the time of its execution.

The Regional Trial Court (RTC) initially ruled in favor of the petitioners, upholding the validity of the deed and the subsequent Transfer Certificate of Title (TCT) in the names of Marcelino and Veronica. However, the Court of Appeals (CA) reversed this decision, declaring the respondents rightful owners of one-half of the property. The CA based its decision on the disparity in the technical descriptions of the property and the impairment of Fortunato’s legitime (legal share of inheritance). The admissibility of OCT No. 352, written in Spanish without translation, was also contested, but the CA deemed it admissible due to the lack of timely objection during the trial. This led to the Supreme Court review.

The Supreme Court addressed several key issues, including the admissibility of the Spanish-language document, the validity of the donation, and the claim of impairment of legitime. Regarding the admissibility of OCT No. 352, the Court cited Section 36, Rule 132 of the Revised Rules of Evidence, emphasizing that an objection to written evidence must be made within three days after notice of the offer. Since the petitioners failed to object to the document’s admissibility on time, they waived their right to do so. Evidence not objected to is deemed admitted and may be validly considered by the court, even if it would have been inadmissible if challenged at the proper time.

Furthermore, the Supreme Court clarified that issues concerning the impairment of legitime should be resolved in a special proceeding for the settlement of estates, not in a civil action for reconveyance and damages. A probate court is the appropriate forum to address matters relating to the settlement of a deceased person’s estate, including the advancement of property. As explained in Natcher v. Court of Appeals, an action for reconveyance is a civil action, while estate settlement involves special proceedings with specific rules outlined in the Rules of Court.

Section 3, Rule 1 of the 1997 Rules of Civil Procedure defines civil action and special proceedings, in this wise:

x x x  a) A civil action is one by which a party sues another for the enforcement or protection of a right, or the prevention or redress of a wrong.

A civil action may either be ordinary or special. Both are governed by the rules for ordinary civil actions, subject to specific rules prescribed for a special civil action.

x x x

c) A special proceeding is a remedy by which a party seeks to establish a status, a right or a particular fact.

The Court, however, delved into the validity of the deed of donation. It reiterated that laws in effect at the time of a contract’s execution govern its validity, not later statutes, unless the latter are specifically intended to have retroactive effect. Therefore, the Old Civil Code, which was in force in 1919 when the donation was made, applies to this case. Under the Old Civil Code, donations propter nuptias of real property must be made in a public instrument specifying the property being donated. Article 633 of the Old Civil Code states that the gift of real property, to be valid, must appear in a public document.

Article 1328 of the Old Civil Code provides that gifts propter nuptias are governed by the rules established in Title 2 of Book 3 of the same Code. Article 633 of that title provides that the gift of real property, in order to be valid, must appear in a public document.

Since the donation in question was made through a private instrument, the Supreme Court declared it void. As such, it did not convey any title to the land to Marcelino and Veronica. Consequently, the cancellation of OCT No. 352 and the issuance of TCT No. 44481 in favor of Marcelino and Veronica lacked legal basis, necessitating the restoration of the original title to spouses Simeon Doronio and Cornelia Gante. The court clarified, however, that a direct reconveyance to either party was not possible at this stage, as the rightful heirs and the extent of their ownership had not been determined in a proper proceeding.

Regarding the respondents’ claim of ownership through acquisitive prescription, the Supreme Court dismissed it, citing that a title registered under the Torrens system cannot be defeated by adverse possession or prescription. OCT No. 352 serves as notice to the whole world, precluding anyone from claiming ignorance of the registration. The Torrens system aims to ensure the integrity and conclusiveness of land titles, preventing the perpetration of fraud against the real owner.

In summary, the Supreme Court reversed the CA’s decision, declaring the private deed of donation propter nuptias null and void. It ordered the Register of Deeds of Pangasinan to cancel TCT No. 44481 and restore OCT No. 352 in the names of Simeon Doronio and Cornelia Gante. The Court emphasized that the determination of the rightful heirs and the extent of their ownership must be resolved in a separate proceeding for the settlement of the estates of the original registered owners.

FAQs

What was the key issue in this case?	The key issue was whether a private deed of donation propter nuptias executed in 1919 validly transferred ownership of real property under the Old Civil Code, which required such donations to be made in a public instrument.
Why was the deed of donation declared void?	The deed was declared void because it was made through a private instrument, not a public instrument, as required by the Old Civil Code for donations of real property propter nuptias.
What is a donation propter nuptias?	A donation propter nuptias is a donation made by reason of marriage, typically to one or both of the future spouses in consideration of the marriage.
What is the significance of the Torrens system in this case?	The Torrens system, which provides for the registration of land titles, ensures that registered titles cannot be defeated by adverse possession or prescription, protecting the integrity of land ownership.
Why couldn’t the respondents claim ownership through acquisitive prescription?	The respondents could not claim ownership through acquisitive prescription because the property was registered under the Torrens system, which protects registered titles from being defeated by adverse possession or prescription.
What happens to the property now that the deed of donation is void?	The property reverts to the original owners, spouses Simeon Doronio and Cornelia Gante, and the determination of the rightful heirs and their respective shares must be resolved in a separate proceeding for the settlement of their estates.
Why was the issue of impairment of legitime not resolved in this case?	The issue of impairment of legitime was not resolved because it should be addressed in a special proceeding for the settlement of estates, not in a civil action for reconveyance and damages.
Was the OCT written in Spanish admissible as evidence?	Yes, because petitioners failed to raise a timely objection to the admissibility of the OCT written in Spanish. Evidence that is not objected to may be deemed admitted and validly considered by the court.
What should the parties do next?	The parties should initiate a special proceeding for the settlement of the estates of spouses Simeon Doronio and Cornelia Gante to determine the rightful heirs and their respective shares in the property.

This case underscores the critical importance of adhering to formal legal requirements when executing contracts, especially those involving real property. The ruling serves as a reminder that the validity of a contract is determined by the laws in effect at the time of its execution, and failure to comply with these laws can render the contract void, leading to significant legal and financial consequences.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: THE HEIRS OF MARCELINO DORONIO VS. HEIRS OF FORTUNATO DORONIO, G.R. No. 169454, December 27, 2007