G.R. No. L-67888 October 8, 1985
IMELDA ONG, ET AL., petitioners, vs. ALFREDO ONG, ET AL., respondents.

FACTS

On February 25, 1976, petitioner Imelda Ong executed a Quitclaim Deed in favor of the minor Sandra Maruzzo, transferring all her rights, title, and interest in a one-half undivided portion of a parcel of land in Makati. The deed stated the consideration as “One (P1.00) Peso and other valuable considerations.” Years later, Imelda Ong revoked this deed and subsequently donated the entire property to her son, Rex Ong-Jimenez. Sandra Maruzzo, through her guardian ad litem Alfredo Ong, filed an action for recovery of ownership, nullification of the donation, and accounting.
Petitioners argued before the trial court that the Quitclaim Deed was essentially a donation requiring acceptance by the donee to be valid. They contended that since Sandra was a minor and legally incapable of acceptance, the deed was null and void. The trial court ruled against them, holding the deed was equivalent to a sale and thus a valid conveyance. This decision was affirmed by the Intermediate Appellate Court.

ISSUE

The core issue is whether the Quitclaim Deed is a valid conveyance of property or a null and void donation for lack of acceptance by the minor donee.

RULING

The Supreme Court affirmed the Appellate Court’s decision, upholding the validity of the Quitclaim Deed. The legal logic proceeds on two key points. First, the deed is not a donation but a conveyance for a valuable consideration. The stated cause is not merely the symbolic one peso but explicitly includes “other valuable considerations.” Under Article 1354 of the Civil Code, a contract is presumed to have a sufficient cause or consideration unless proven otherwise. The party alleging lack of consideration bears the burden of proof, which petitioners failed to discharge. The execution of a public instrument purporting to convey ownership is prima facie evidence of a valuable consideration. The nominal one-peso consideration, a common practice in deeds, does not invalidate the contract, as liberality can itself be a sufficient cause.
Second, even assuming arguendo that the deed constituted a donation, it would still be valid. The Court distinguished between types of donations. Article 741 of the Civil Code, which requires acceptance by the minor’s parents or legal representatives, applies only to onerous or conditional donations where the donee assumes charges or obligations. The Quitclaim Deed in question imposed no conditions or burdens on the donee; it was a simple or pure donation. For such pure donations, formal acceptance by a legal representative is not indispensable for validity, as established in Kapunan vs. Casilan and Court of Appeals. The donor requires no right to be protected, and the donee assumes no obligation. Therefore, the minor’s incapacity did not invalidate the transfer.