CARDINEZ V. SPOUSES CARDINEZ
G.R. No. 213001, August 4, 2021
SECOND DIVISION, HERNANDO
J.
Property; Donation;
Consent
Principle: This case underscores the importance of voluntary and informed consent in donations. The court's decision to revoke the donation in this case serves as a reminder of the significance of genuine consent in the transfer of property rights through donations.
After the death of Simeona Cardinez,
her sons Prudencio, Florentino, and Valentin inherited and divided the land
among themselves. In 1994, Valentin asked Prudencio to donate a ten-square
meter portion of his land that was being encroached by Valentin's balcony.
Prudencio, trusting his brother, agreed and signed a document without
understanding its contents. Prudencio later discovered that the document he
signed was a Deed of Donation, allegedly transferring his inherited portion to
Valentin's children. The Deed of Donation was not read or understood by
Prudencio and his wife Cresencia when they signed it.
When Prudencio discovered this, he
sought to revoke the donation, alleging lack of consent. The trial court ruled
in his favor of Prudencio, revoking the donation due to fraudulent means. Court
of Appeals affirmed the decision.
Whether the donation made by Spouses
Cardinez should be revoked due to lack of consent.
YES. The Supreme Court affirmed the ruling of the
trial court and upheld the revocation of the donation. Deed of Donation is void
ab initio in the absence of respondents' consent.
The court held that Prudencio’s
testimony provided sufficient evidence to prove that the donation was fraudulently
executed. The SC held that respondents did not give their consent to the
donation of their land to petitioners. Hence, no valid donation had transpired
between the parties.
It is clear that respondents did not
donate their land. They never understood the full import of the document they
signed because it was neither shown to them nor read by either Valenin or the
notary public. Considering that they did not give their consent at all to the
Deed of Donation, it is therefore null and void.
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