Republic v.

Guzman

FACTS:

 David Rey Guzman, a natural-born American citizen, is the son of the spouses
Simeon Guzman (naturalized American) and Helen Meyers Guzman (American
citizen). In 1968, Simeon died leaving to his heirs, Helen and David, an estate
consisting of several parcels of land in Bulacan.
 In 1970, Helen and David executed a Deed of Extrajudicial Settlement of the Estate,
dividing and adjudicating to themselves all of the property, and registered it to the
RD a year after.
 In 1981, Helen executed a Deed of Quitclaim, assigning, transferring and conveying
her ½ share of the properties to David. But since it was not registered, she executed
another Deed of Quitclaim to confirm the first.
 In 1994, Atty. Batongbacal wrote the OSG and furnished it with documents showing
that David’s ownership of ½ of the estate was defective. He argued that Art. XII of
the Constitution only allows Filipinos to acquire private lands in the country. The only
instances when a foreigner may acquire private property are by hereditary
succession and if he was formerly a natural-born citizen who lost his Filipino
citizenship. Moreover, it contends that the Deeds of Quitclaim executed by Helen
were really donations inter vivos.
 Republic filed with RTC a Petition for Escheat praying that ½ of David’s interest be
forfeited in its favor. RTC dismissed. CA affirmed.

ISSUE: Whether or not there was a donation inter vivos

HELD: NO.

Not all the elements of a donation are present. The transfer of the properties by virtue of
a Deed of Quitclaim resulted in the (1) reduction of her patrimony as donor and the (2)
consequent increase in the patrimony of David as donee.

However, Helen’s (3) intention to perform an act of liberality in favor of David was not
sufficiently established. The 2 Quitclaims reveal that Helen intended to convey to her
son certain parcels of land and to re-affirm it, she executed a waiver and renunciation of
her rights over these properties. It is clear that Helen merely contemplated a waiver of
her rights, title, interest over the lands in favor of David, not a donation. She was also
aware that donation was not possible.
Moreover, the essential element of acceptance in the proper form and registration to
make the donation valid is lacking. The SPA executed by David in favor of Atty. Abela
was not his acceptance, but an acknowledgment that David owns the property referred
to and that he authorizes Atty. Abela to sell the same in his name. Further, there was
nothing in the SPA to show that he indeed accept the donation.

However, the inexistence of a donation does not make the repudiation of Helen in favor
David valid. There is NO valid repudiation of inheritance as Helen had already accepted
her share of the inheritance when she, together with David, executed a Deed of
Extrajudicial Settlement of the Estate, dividing and adjudicating between them all the
properties. By virtue of that settlement, the properties were registered in their names
and for 11 years, they possessed the land in the concept of owner. Thus, the 2
Quitclaims have no legal force and effect. Helen still owns ½ of the property.

NOTES:
Three essential elements of a donation:

1. Reduction in the patrimony of the donor

2. Increase in the patrimony of the done
3. Intent to do an act of liberality or animus donandi

It is also required that the donation be made in a public document and that its
acceptance be made in the same deed of donation or in a separate public document,
which has to be recorded as well.