233.

Spouses Eduarte vs CA despite the fact that they are classified as crimes against personal liberty
G.R. No. 105944 and security under the RPC.
February 9, 1996 
TOPIC: Revocation of Donation Eduarte and the Church still won although the donation was deemed by
Petitioners: SPOUSES ROMULO AND SALLY EDUARTE the Court to be revocable.
Respondent: CA and PEDRO CALAPINE  The Court applied the CHAIN OF TITLE THEORY because the lands were
Ponente: Francisco, J. registered lands and it has already passed from the forger (Doria) to
innocent purchasers for value (Eduarte, et al.).

FACTS:
 Pedro Calapine was the registered owner of a parcel of land.
 He executed a deed of donation inter vivos of ½ of the land to his niece,
Helen Doria.
 Subsequently, he executed another deed of donation inter vivos ceding
the other ½ of the property to Helen Doria.
 Helen Doria donated a portion of the lot (157 sqm) to the Calauan
Christian Reformed Church.
 Helen Doria sold to Petitioner Eduarte and conveyed the remaining
portion save some 700 meters for her residence.
 Pedro Calapine sought to annul the sale and donation to Eduarte and
CCRC on the ground that the deed of donation was a forgery and that
Doria was unworthy of his liberality claiming ingratitude (commission of
offense against the person, honor or property of donor)

ISSUE:
W/N the falsification of public document committed by Doria is an act of
ingratitude against Calapine (considering that falsification is a crime against public
interest)?

RULING:
YES
 In commentaries of Tolentino, it is said that “all crimes which offend the
donor show ingratitude and are causes of revocation.”
 Petitioner attempted to categorize the offenses according to their
classification under the RPC by deleting the first sentence.
 However, this is unwarranted considering that illegal detention, threats
and coercion are considered crimes against the person of the donor