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REPUBLIC v.

GUZMAN

HELD: NO.

Three essential elements of a donation:


1. Reduction in the patrimony of the donor
2. Increase in the patrimony of the donee
3. Intent to do an act of liberality or animus
donandi

Not all the elements of a donation are present.


The transfer of the properties by virtue of a Deed
of Quitclaim resulted in the

It is also required that the donation be made in a


public document and that its acceptance be made
in the same deed of donation or in a separate
public document, which has to be recorded as
well.

(1) reduction of her patrimony as donor and the


(2) consequent increase in the patrimony of
David as donee. However, Helens (3) intention to
perform an act of liberality in favor of David was
not sufficiently established.
The 2 Quitclaims reveal that Helen intended to
convey to her son certain parcels of land and to
re-affirm it, she executed a waiver and
renunciation of her rights over these properties.

FACTS:
David Rey Guzman, a natural-born American
citizen, is the son of the spouses Simeon
Guzman (naturalized American) and Helen
Meyers Guzman (American citizen). In 1968,
Simeon died leaving to his heirs, Helen and
David, an estate consisting of several parcels of
land in Bulacan.
In 1970, Helen and David executed a Deed of
Extrajudicial Settlement of the Estate, dividing
and adjudicating to themselves all of the property,
and registered it to the RD a year after.
In 1981, Helen executed a Deed of Quitclaim,
assigning, transferring and conveying her
share of the properties to David. But since it was
not registered, she executed another Deed of
Quitclaim to confirm the first.
In 1994, Atty. Batongbacal wrote the OSG
andfurnished it with documents showing that
Davids ownership of of the estate was
defective.
He argued that Art. XII of the Constitution only
allows Filipinos to acquire private lands in the
country. The only instances when a foreigner may
acquire private property are by hereditary
succession and if he was formerly a natural-born
citizen who lost his Filipino citizenship. Moreover,
it contends that the Deeds of Quitclaim executed
by Helen were really donations inter vivos.
Republic filed with RTC a Petition for Escheat
praying that of Davids interest be forfeited in
its favor. RTC dismissed. CA affirmed.
ISSUE: Whether or not there was a donation inter
vivos

It is clear that Helen merely contemplated a


waiver of her rights, title, interest over the lands in
favor of David, not a donation. She was also
aware that donation was not possible.
Moreover, the essential element of acceptance in
the proper form and registration to make the
donation valid is lacking.
The SPA executed by David in favor of Atty. Abela
was not his acceptance, but an acknowledgment
that David owns the property referred to and that
he authorizes Atty. Abela to sell the same in his
name. Further, there was nothing in the SPA to
show that he indeed accept the donation.
However, the inexistence of a donation does not
make the repudiation of Helen in favor David
valid. There is NO valid repudiation of inheritance
as Helen had already accepted her share of the
inheritance when she, together with David,
executed a Deed of Extrajudicial Settlement of
the Estate, dividing and adjudicating between
them all the properties. By virtue of that
settlement, the properties were registered in their
names and for 11 years, they possessed the land
in the concept of owner. Thus, the 2 Quitclaims
have no legal force and effect. Helen still owns
of the property.