Republic v.

Guzman
Facts:
David Guzman (David) is a natural-born American citizen, the son of
Simeon, a naturalized American Citizen, and Helen Guzman (Helen), an
American citizen. Simeon died intestate, leaving as sole heirs David and
Helen. Thus, sometime after the death of Simeon, David and Helen executed
an Extrajudicial Settlement of Estate. Thereafter, Helen executed two (2)
Quitclaim Deeds which purported that she relinquished her share of the
properties. Consequently, David executed a Special Power of Attorney to the
effect that he declares himself the owner of the whole property and
authorizing his attorney to sell the property on his behalf.
A certain person wrote to the Office of the Solicitor General (OSG)
alleging that David had a defective title over share, on the basis of which
the Government filed a petition for escheat with the Regional Trial Court
(RTC) to the extent of the one-half share because it was argued to be a
donation. The trial court dismissed the petition on the ground that the 2
quitclaims were of no legal force and effect and that the ownership
remained with Helen.
The Court of Appeals (CA) affirmed the decision of the RTC. Hence,
the Republic appealed to the Supreme Court (SC), alleging the same defect
on Davids title on the ground that he is an alien, who could not acquire
private lands through donation.
Issue:
Are the RTC and CA correct in dismissing the petition for escheat of
the Republic?
Ruling and Discussion:
Yes, the RTC and CA are correct in dismissing the petition for escheat.
First, David and Helen are admittedly aliens, with a decedent who was
a former Filipino who had, during his lifetime, properties (specifically
private lands) while he was still a Filipino. By way of exception from the
general rule, aliens may only acquire lands (2) through hereditary
succession or (2) where he was formerly a natural-born Filipino. In this
case, Simeon, the decedent had a vested right on the property, he being
formerly a natural-born Filipino. Thus, when he died, he had the right over
the property which he could transmit by way of succession. David and
Helen, on the other hand, despite being not natural-born Filipinos could
acquire the same by way of hereditary succession. Therefore, the two
validly owned the property.
Second, on the question of the Quitclaim, which was argued to be a
donation from Helen to David, the SC ruled that the same was not a
donation. For there to be donation, the following requisites must concur: (1)
that there is a decrease in the patrimony of the donor, (2) that there is an
increase in the patrimony of the done and (3) that there is an animus
donandi. In the present case, the SC ruled that animus donandi is not
present because nowhere in the Quitclaims nor in the testimony of Helen
can the intention be discerned. In fact, it is negated by the fact that she said
in her deposition that she knew that she was not legally capable in the

Philippines to effect the donation and that if she intended to do so, she
could have sold her interest to David and gave her the money.
Third, additional requirements as to form are imposed by law for a
certain donation to be valid: that it must appear in a public instrument, as
well as the acceptance, if the property donated is a real property, regardless
of the amount. In the case, the quitclaims, being without any import of
donation could not be regarded as the document of donation, and the
Special Power of Attorney could not be regarded as the acceptance, for
nowhere in the said documents was it stated, expressly or impliedly, that a
donation was being made and that the same was accepted. Thus, there was
no valid donation.
However, just because there was no valid donation, it does not mean
the repudiation of the inheritance was also valid. It was ruled that the
repudiation could not be made after the heir accepted the inheritance, for
by accepting it, the same had become irrevocable, which could not be
impugned except on the ground of vitiated consent or the discovery of an
unknown will. Thus, the ownership of the share of Helen remained with
her, as the Quitclaim did not have any legal force and effect.
Lastly, the fact that there was no valid repudiation cannot necessarily
mean that the property had become res nullius to be a proper subject of
escheat. As held earlier, the ownership thereof remained validly in Helen.
Thus, the petition for escheat does not have a legal basis. Dismissal thereof
was proper.