G.R. No. L-20122, April 28, 1969
FELICIANO A. CASTRO, petitioner, vs. THE COURT OF APPEALS, EUGENIA SORIANO DE GOMEZ, SOCORRO A. CASTRO and THE HEIRS OF THE LATE ANTONIO VENTENILLA, JUSTO V. SISON, SUSANA V. SISON, JOSE V. SISON, SOCORRO V. SISON DE VERA, ELIAS VENTENILLA, MARIA VENTENILLA, JUAN VENTENILLA, NIEVA VENTENILLA, GUADALUPE VENTENILLA, VICENTE VENTENILLA, ROSARIO VENTENILLA, MANUEL SORIANO, JOSE SORIANO, JR., CESAR SORIANO, OLIVA SORIANO, SOLEDAD SORIANO, CARMEN SORIANO, ANGELES SORIANO, BENJAMIN S. VILORIA and PAZ S. VILORIA, respondents.

FACTS

Alejandra Austria, widow of Antonio Ventenilla, filed an original application for registration and confirmation of title over ten parcels of land. Socorro A. Castro opposed, claiming the lands were donated to her by Austria in 1939. The trial court initially ordered registration in Castro’s name, subject to Austria’s lifetime usufruct. Subsequently, heirs of Antonio Ventenilla (oppositors) successfully petitioned to set aside the decision and oppose the application, claiming the lands were owned by Ventenilla, bequeathed in usufruct to Austria, and upon her death should pass to them as his heirs. The trial court, in a 1959 decision, rejected both Castro’s and the oppositors’ claims without deciding title for registration. Only Castro appealed to the Court of Appeals, which dismissed the appeal. The case was elevated to the Supreme Court on petition for review. The ten parcels were classified: Parcels 1, 2, 3, and 10 were agreed by parties to have passed to Austria after Ventenilla’s death by virtue of his probated will. Parcels 4, 5, 6, 7, 8, and 9 were disputed, with Castro claiming Austria acquired them by purchase and oppositors claiming they belonged to Ventenilla.

ISSUE

1. Whether Alejandra Austria owned Parcels 1, 2, 3, and 10 in fee simple as residuary legatee or was merely a life usufructuary, with naked ownership in the oppositors.
2. Whether Alejandra Austria had sufficient registrable title to Parcels 4, 5, 6, 7, 8, and 9.
3. Whether the donation from Alejandra Austria to Socorro A. Castro was inter vivos or mortis causa, and consequently valid or void.

RULING

1. Regarding Parcels 1, 2, 3, and 10: The Supreme Court ruled that Alejandra Austria was the owner in fee simple as the residuary legatee under the will of Antonio Ventenilla. This issue was already settled with finality in a previous case (G.R. No. L-10018, Austria v. Heirs of Antonio Ventenilla), which declared her the residuary legatee of all remaining properties of the estate, making the matter res judicata. Her continuous possession as owner constituted sufficient proof of title for registration.
2. Regarding Parcels 4, 5, 6, 7, 8, and 9: The Supreme Court ruled that Alejandra Austria had sufficient registrable title. The documentary evidence showed she acquired them by purchase, and testimonial evidence confirmed her long possession as owner. Even assuming these parcels belonged to Ventenilla, they would have passed to Austria as the residuary heir under his will, and her possession in concept of owner constituted sufficient registrable title.
3. Regarding the Donation: The Supreme Court ruled the donation was inter vivos and therefore valid. The donor intended to and did dispose of her properties irrevocably in favor of the donee, subject only to conditions, including the reservation of usufruct (enjoyment of products) during the donor’s lifetime. The postponement of enjoyment until the donor’s death did not make the donation mortis causa, as the naked ownership was transferred immediately upon execution. The donation’s main consideration was services rendered and affection, not the donor’s death.
DISPOSITIVE:
The decision of the Court of Appeals was REVERSED. The lands described in the original application for registration were ordered registered in the name of the Intestate Estate of Socorro A. Castro, represented by the petitioner as administrator. No costs.