GR 81401; (May, 1990) (Digest)
G.R. No. 81401 May 18, 1990
VIRGINIA FRANCO VDA. DE ARCEO, et al., petitioners, vs. HON. COURT OF APPEALS, PEDRO M. ARCEO, et al., respondents.
FACTS
The case involves four parcels of unregistered land originally owned by spouses Abdon Arceo and Escolastica Geronimo. Upon their deaths, conflicting claims arose between two sets of their grandchildren. Petitioners, the widow and children of grandson Jose Arceo, based their claim on a 1941 deed of donation inter vivos (Exhibit “J”) in favor of Jose, and a subsequent 1950 deed (Exhibit “T”). They argued Jose had possessed the properties openly since 1942. Private respondents, the other grandchildren, opposed the registration, relying on a purported 1941 deed of donation mortis causa (Exhibit “1”) which revoked the earlier donation and named all grandchildren as donees.
The cadastral court rejected all three documentary exhibits and distributed the properties according to the rules of intestate succession. The Court of Appeals affirmed this decision. The petitioners then elevated the case to the Supreme Court, arguing that the cadastral court lacked jurisdiction to determine ownership and that their title was acquired through prescription and the valid donations.
ISSUE
The primary issue is whether the cadastral court had jurisdiction to resolve the conflicting claims of ownership. The secondary issue is determining the rightful owner of the disputed properties based on the validity and effect of the competing deeds of donation.
RULING
The Supreme Court reversed the Court of Appeals. On jurisdiction, the Court ruled that under the Property Registration Decree, a regional trial court acting as a land registration court possesses broad jurisdiction to resolve all questions arising from an application for registration, including issues of ownership. This is especially true when, as here, the question of ownership is inextricably linked to the right of registration, and the parties have fully presented their evidence on the controversy.
On the merits, the Court held that Exhibit “J”, a donation inter vivos in favor of Jose Arceo, was valid and irrevocable. A donation inter vivos, once accepted, becomes irrevocable except on specific grounds not present in this case. The Court found no legal basis to invalidate Exhibit “J”. In contrast, the purported revocatory instrument, Exhibit “1”, a donation mortis causa, could not lawfully revoke the prior irrevocable donation. The Court also noted the factual finding of the Court of Appeals that Exhibit “T” was defective. Consequently, the properties should be awarded to the petitioners as successors-in-interest of the donee, Jose Arceo, in accordance with the terms of the valid donation inter vivos (Exhibit “J”). The Court set aside the appellate decision and ordered the distribution of the properties pursuant to Exhibit “J”.