The Heirs of Salud Dizon Salamat v. Natividad Dizon Tamayo

Summary

This case involves a property dispute among the heirs of Agustin Dizon who died intestate in 1942. The main issue was whether respondent Natividad Dizon Tamayo validly received a parcel of land through an alleged oral donation from her father in 1936. Two of her siblings had previously sold their hereditary rights to another sister, Salud. When petitioners sought partition of the estate, Natividad claimed ownership of the disputed lot based on the alleged oral donation and presented a private document from her brother Eduardo as proof. The Supreme Court reversed the lower courts' decisions, holding that donations of immovable property must comply with Article 749 of the Civil Code requiring execution in a public document. The Court found the supporting document unreliable due to unexplained alterations and ruled that Natividad's possession was not adverse to her co-heirs, thus she could not acquire ownership through prescription. The property was declared part of Agustin Dizon's estate subject to partition.