CIVIL LAW REVIEW 1 (LEGARDA)

205 Mateo v. Lagua

G.R. No. L-26270, October 30, 1969
Topic: Donations Propter Nuptias
Doctrine: Donations Propter Nuptias may be reduced for
inofficiousness, if such donation infringes upon the
legitime of a compulsory heir.

Facts:
 Cipriano Lagua owned 3 parcels in Asingan.
Cipriano then donated the 2 disputed lots to
their son, Alejandro Lagua, in consideration of
Alejandro’s marriage to Bonifacia Mateo. The
title of the land, however, remained in Cipriano’s
name.
 Alejandro died; thereafter the father Cipriano
took over the farming duties in the donated lots
and provided the widow Bonifacia her share in
the harvest. Eventually, Cipriano refused to
deliver Bonifacia’s share. Hence Bonifacia sued
Cipriano to obtain sole possession of the lots.
 Cipriano then sold the same 2 disputed lots to his
other son, Gervasio, and TCTs were issued in
Gervasio’s name. Hence, Bonifacia sought
annulment of the sale to Gervasio. The Trial
court ruled in favor of Bonifacia and ordered
Gervasio to vacate and deliver possession of the
land to Bonifacia.
 Gervasio now sues Bonifacia, seeking a reduction
of the donation of the 2 lots. According to
Gervasio, when their father Cipriano initially
donated the 2 lots to Alejandro and Bonifacia,
Cipriano inadvertently prejudiced Gervasio’s
legitime.

Issue: Can a Donation Propter Nuptias be reduced for

being inofficious?
Held/Ratio: YES.
 A donation propter nuptias properly may be
reduced for being inofficious.
 Contrary to the views of Bonifacia, donations
propter nuptias are without onerous
consideration, the marriage being merely the
occasion or motive for the donation, not its
causa.
 Being liberalities, they remain subject to
reduction for inofficiousness upon the donor's
death, if they should infringe the legitime of a
forced heir.