Spouses Eduarte Vs CA
Spouses Eduarte Vs CA
Spouses Eduarte Vs CA
Spouses Eduarte vs CA despite the fact that they are classified as crimes against personal liberty
G.R. No. 105944 and security under the RPC.
February 9, 1996
TOPIC: Revocation of Donation Eduarte and the Church still won although the donation was deemed by
Petitioners: SPOUSES ROMULO AND SALLY EDUARTE the Court to be revocable.
Respondent: CA and PEDRO CALAPINE The Court applied the CHAIN OF TITLE THEORY because the lands were
Ponente: Francisco, J. registered lands and it has already passed from the forger (Doria) to
innocent purchasers for value (Eduarte, et al.).
FACTS:
Pedro Calapine was the registered owner of a parcel of land.
He executed a deed of donation inter vivos of ½ of the land to his niece,
Helen Doria.
Subsequently, he executed another deed of donation inter vivos ceding
the other ½ of the property to Helen Doria.
Helen Doria donated a portion of the lot (157 sqm) to the Calauan
Christian Reformed Church.
Helen Doria sold to Petitioner Eduarte and conveyed the remaining
portion save some 700 meters for her residence.
Pedro Calapine sought to annul the sale and donation to Eduarte and
CCRC on the ground that the deed of donation was a forgery and that
Doria was unworthy of his liberality claiming ingratitude (commission of
offense against the person, honor or property of donor)
ISSUE:
W/N the falsification of public document committed by Doria is an act of
ingratitude against Calapine (considering that falsification is a crime against public
interest)?
RULING:
YES
In commentaries of Tolentino, it is said that “all crimes which offend the
donor show ingratitude and are causes of revocation.”
Petitioner attempted to categorize the offenses according to their
classification under the RPC by deleting the first sentence.
However, this is unwarranted considering that illegal detention, threats
and coercion are considered crimes against the person of the donor