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G.R. NO. 150416. July 21, 2006 (Case Brief - Digest)

The case involves a property dispute between two Seventh Day Adventist organizations over a property in Agusan del Sur, originally donated to an unincorporated entity. The Supreme Court ruled that the donation was void due to the lack of juridical personality of the donee at the time, and upheld the validity of the subsequent sale of the property. The decision emphasized that a donation to a non-existent entity is invalid and highlighted the legal requirements for valid donations and corporate existence.

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58 views2 pages

G.R. NO. 150416. July 21, 2006 (Case Brief - Digest)

The case involves a property dispute between two Seventh Day Adventist organizations over a property in Agusan del Sur, originally donated to an unincorporated entity. The Supreme Court ruled that the donation was void due to the lack of juridical personality of the donee at the time, and upheld the validity of the subsequent sale of the property. The decision emphasized that a donation to a non-existent entity is invalid and highlighted the legal requirements for valid donations and corporate existence.

Uploaded by

dandan.tuazon023
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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G.R. NO. 150416.

July 21, 2006 (Case Brief / Digest)

Title: Seventh Day Adventist Conference Church of Southern Philippines, Inc. vs.
Northeastern Mindanao Mission of Seventh Day Adventist, Inc.

Facts:
This case pertains to a dispute over a property in Bayugan, Agusan del Sur, covered by
Transfer Certificate of Title (TCT) No. 4468, originally owned by Felix Cosio and his wife,
Felisa Cuysona. On April 21, 1959, they donated the property to the South Philippine Union
Mission of Seventh Day Adventist Church of Bayugan Esperanza, Agusan (SPUM-SDA
Bayugan), as evidenced by a deed of donation. The donation was purportedly accepted by an
elder of the Church, Liberato Rayos.

Two decades later, on February 28, 1980, the same spouses sold the property to the
Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM), and TCT
No. 4468 was issued in their name. The petitioners, claiming to be the alleged donee’s
successors-in-interest, initiated a lawsuit to assert ownership over the property. They
argued that SPUM-SDA Bayugan, at the time of the donation, was not incorporated and thus
had no juridical personality to be a donee.

The petitioners filed a suit for cancellation of title, quieting of ownership and possession,
declaratory relief, and reconveyance with a prayer for preliminary injunction and damages
(Civil Case No. 63) in the RTC of Bayugan, Agusan del Sur. The trial court ruled in favor of
the respondents, upholding the sale. On appeal, the CA affirmed the RTC’s decision but
deleted the award of moral damages and attorney’s fees. A motion for reconsideration by
the petitioners was subsequently denied, leading to this petition for review before the
Supreme Court.

Issues:
1. Whether the Court should review the validity of the deed of donation although it was not
raised as an issue on appeal.
2. Whether the alleged donation to the petitioners’ predecessors was valid.
3. Whether the petitioners qualify as a de facto corporation to benefit from the donation.
4. Whether the sale of the property to the respondents (SDA-NEMM) was valid and should
be upheld.

Court’s Decision:
The Supreme Court denied the petition and ruled in favor of respondents (SDA-NEMM). The
Court concluded that the deed of donation was void, as it was made in favor of an entity that

© 2024 - batas.org | 1
G.R. NO. 150416. July 21, 2006 (Case Brief / Digest)

did not exist at the time. There were also no proof of attempts to incorporate, or any
issuance of a certificate of incorporation, which is essential for the existence of a de facto
corporation. Furthermore, the Court affirmed that the sale was valid as there were no
convincing disputes over the trial court’s findings, and an appeal to the Supreme Court
generally only opens questions of law, not facts.

Doctrine:
1. A donation made to a non-existent entity is void.
2. An organization that is not registered with the Securities and Exchange Commission
(SEC) cannot be considered a corporation in any concept, not even as a corporation de
facto.
3. A Certificate of Title is generally conclusive evidence of title to land.

Class Notes:
– A valid donation requires a capacitated donor and donee, a donation deed, and acceptance
by the donee’s representative.
– A de facto corporation must have a valid law under which it can be incorporated, an
attempt in good faith to incorporate, and the assumption of corporate powers.
– In real estate transactions, both donation and sale are modes of transferring ownership;
however, all legal requirements must be met for them to be effective.
– A Certificate of Title is considered conclusive evidence of the ownership of the land
covered by it unless it is challenged in a direct proceeding.

Historical Background:
The historical context of the case reflects the conditions of the legal framework concerning
religious organizations and their capacity to own property during the mid-20th century in
the Philippines. This case illustrates the implications of the implementation of corporate law
for religious entities, echoing the importance of the sanctity of the land titling system and
the acquisition of juridical personality through proper incorporation.

© 2024 - batas.org | 2

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