**Ricky Q. Quilala vs. Gliceria Alcantara, Leonora Alcantara, Ines Reyes, and Jose Reyes** – G.R. No. 129749, December 20, 1999
### **Facts:**
1. *Donation Execution*:
– On February 20, 1981, Catalina Quilala executed a “Donation of Real Property Inter Vivos” in favor of Violeta Quilala for a 94-square-meter parcel of land in Sta. Cruz, Manila.
– The deed of donation was two pages long: the first page contained the deed and signatures of Catalina, Violeta, and two witnesses; the second page contained the acknowledgment with signatures on the margins by Catalina, Violeta, and the two witnesses.
2. *Registration of Title*:
– The deed was registered with the Register of Deeds, leading to the cancellation of TCT No. 17214 and issuance of TCT No. 143015 in Violeta’s name.
3. *Deaths*:
– Catalina Quilala died on November 7, 1983, and Violeta Quilala died on May 22, 1984. Ricky Quilala, the petitioner, claimed to be Violeta’s surviving son.
4. *Respondents’ Actions*:
– Respondents Gliceria Alcantara, Leonora Alcantara, Ines Reyes, and Juan Reyes executed a deed of extrajudicial settlement, claiming to be Catalina’s only surviving relatives within the fourth civil degree of consanguinity.
5. *Civil Case Initiation*:
– On September 13, 1984, respondents filed an action to nullify the donation and cancel TCT No. 143015, registering the case as Civil Case No. 84-26603 at the Regional Trial Court of Manila, Branch 17. Guillermo T. San Pedro, the Registrar of Deeds of Manila, was initially a defendant but was later dropped from the case.
6. *Trial Court Decision*:
– The trial court ruled the donation null and void due to a lack of proper acceptance from Violeta in a public instrument.
– It also found that respondents were Catalina’s first cousins and that the donated property could not be registered in their favor via extrajudicial settlement.
– Ricky Quilala’s counterclaim was dismissed.
7. *Appeal*:
– Ricky Quilala appealed the decision. The Court of Appeals affirmed the decision with modification, dismissing the complaint for lack of cause of action without prejudice to filing probate proceedings for Catalina’s will.
8. *Petition to Supreme Court*:
– Ricky Quilala then filed a petition for review with the Supreme Court, raising issues about the registrability of the deed of donation and the factual assertion of Violeta being Catalina’s daughter.
### **Issues:**
1. Whether the deed of donation inter vivos was valid and registrable.
2. Whether the acceptance of the donation by Violeta Quilala was sufficient in the absence of her acknowledgment before the notary public and its impact on the donation’s validity.
3. Whether Violeta Quilala was legally considered the daughter of Catalina Quilala.
### **Court’s Decision:**
**Issue 1 & 2: Validity and Registrability of the Deed of Donation**
– The Supreme Court reversed the lower courts and declared the deed of donation valid and registrable.
– The Court emphasized that the acceptance by the donee (Violeta) must be indicated either in the same deed or in a separate public document. The donation becomes revocable if the donee fails to accept during the lifetimes of both parties.
– The deed in question contained the requisite acceptance by Violeta clearly stated in the document, and all parties signed all pages of the document.
– Section 112 of PD 1529 was cited, addressing the notarization requirements for the instrument. The acknowledgment by Catalina and the signatures on the margins by all signatories, though some not in the specified margin, complied significantly enough to meet the law’s intent.
– Despite the fact that Violeta’s acknowledgment before the notary was absent, the deed remained a public instrument and thus valid.
**Issue 3: Legal Relationship of Violeta and Catalina**
– The Court refrained from making determinations about familial relationships, which were factual matters requiring evidence and best addressed in proper probate or settlement proceedings.
**Final Disposition:**
– The Supreme Court granted Ricky Quilala’s petition, reversed the decisions of the lower courts, and dismissed Civil Case No. 84-26603.
### **Doctrine:**
1. **Notarization and Deed Validity:**
– The signatures authenticating each page of a deed ensure its contents remain tamper-proof and thereby retain its validity, despite technical departures in applying margins for signatures.
2. **Acceptance in Donation:**
– A donation matures into ownership transfer upon acknowledgment and acceptance by the donee in a public document, even if the acknowledgment of the donee before a notary public is absent.
### **Class Notes:**
– **Requirements for Donation of Immovable Property:**
– Governed by Civil Code Article 749 – must be made in a public instrument.
– Deed must specify the property and the charges borne by the donee.
– **Acceptance in Donation:**
– Can be in the same public instrument or separate document.
– Validity arises once the donor is informed of acceptance, should occur in the donor and donee’s lifetime.
– **Notarization:**
– Under PD 1529, deeds affecting land must be in public form, signed, and properly acknowledged; while marginal signatures are required, placement discrepancies can be overlooked if document integrity is intact.
– **Collation:**
– Any property donated inter vivos is subject to the process of collation upon the donor’s death as part of inheritance discussions.
### **Historical Background:**
The context of the case places it during a period of legal refinement in property and inheritance law in the Philippines, reflecting the stringent requirements for notarization and the formal process of property transfer to avoid fraud and ensure legal clarity during succession and estate distribution. This case exemplifies the rigor of adherence to technical legal procedures in significant legal documentations like donations of immovable property.
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