GR 150416; (July, 2006) (Digest)
G.R. No. 150416 ; July 21, 2006
SEVENTH DAY ADVENTIST CONFERENCE CHURCH OF SOUTHERN PHILIPPINES, INC., et al., petitioners, vs. NORTHEASTERN MINDANAO MISSION OF SEVENTH DAY ADVENTIST, INC., et al., Respondents.
FACTS
The case involves a parcel of land originally owned by spouses Felix Cosio and Felisa Cuysona. On April 21, 1959, the spouses executed a deed of donation over the property in favor of the “South Philippine Union Mission of Seventh Day Adventist Church of Bayugan Esperanza, Agusan” (SPUM-SDA Bayugan). The donation was allegedly accepted by an elder of the church. However, on February 28, 1980, the same spouses sold the identical property to respondent Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM), which subsequently obtained a Transfer Certificate of Title.
Petitioners, claiming to be successors-in-interest to the original donee, SPUM-SDA Bayugan, filed a suit for cancellation of title, quieting of ownership, and reconveyance against respondents. They asserted ownership based on the 1959 donation. Respondents countered that the donation was void because the donee, SPUM-SDA Bayugan, was not a juridical person at the time of the donation, having not been incorporated.
ISSUE
The core issue is whether the 1959 donation was valid, thereby vesting ownership in petitioners’ predecessors, or whether the subsequent 1980 sale to respondents should be upheld.
RULING
The Supreme Court upheld the validity of the sale to respondents and declared the 1959 donation void. The legal logic is anchored on the principle that a donation requires a donee with juridical personality to accept the gift. At the time of the donation in 1959, SPUM-SDA Bayugan was not incorporated and had no legal existence. The Court rejected petitioners’ argument that the donee was a de facto corporation, noting the stringent requirements for such status: (1) a valid law for incorporation, (2) a good faith attempt to incorporate, and (3) an assumption of corporate powers. The Court found no proof of any attempt to incorporate SPUM-SDA Bayugan at the time of the donation, such as the filing of articles of incorporation. Without a certificate of incorporation, an organization cannot be considered a corporation in any sense, not even de facto. Consequently, there was no valid donee capable of accepting the donation, rendering it null and void. Petitioners could not claim succession to a non-existent entity. Since the donation was invalid, the spouses Cosio remained the owners and possessed the capacity to validly sell the property to respondents in 1980. The sale, being supported by a valuable consideration and resulting in the issuance of a title, was thus upheld.