LAW ON PROPERTY | EDUARTE V. COURT OF APPEALS 253 SCRA 391, FEBRUARY 9, 1996

EDUARTE V. COURT OF APPEALS

253 SCRA 391, FEBRUARY 9, 1996

 

TOPIC/DOCTRINE

All crimes which offend the donor show ingratitude and are causes for revocation.

 

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 protion of the lot (157 sqm) to the Calauan Christian Reformed Church. Helen Doria sold and conveyed the remaining portion save some 700 meters for his 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 [par. 1])

 

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.

The court ruled that as noted in the aforecited opinion “all crimes which offend the donor show ingratitude and are causes for revocation.” Petitioners’ attempt to categorize the offenses according to their classification under the Revised Penal Code is therefore unwarranted considering that illegal detention, threats and coercion are considered as crimes against the person of the donor despite the fact that they are classified as crimes against personal liberty and security under the Revised Penal Code.







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