Sps. Agripino Gestopa v. Court of Appeals

Summary

The Supreme Court resolved whether a 1973 donation was inter vivos or mortis causa and whether its subsequent revocation was valid. Spouses Diego and Catalina Danlag donated six parcels of land to Mercedes Danlag-Pilapil, reserving lifetime usufruct and requiring consent for sale. Later, they sold two parcels to the Gestopa spouses and attempted revocation. The trial court ruled the donation was mortis causa and validly revoked, but the Court of Appeals reversed. The Supreme Court affirmed the appellate court, holding that the donation was inter vivos based on comprehensive analysis of the deed's provisions: the granting clause showed love and affection, reservation of usufruct indicated transfer of naked ownership, donor reserved sufficient properties, and donee accepted the donation. The revocation was invalid as it failed to invoke proper grounds under Articles 765 and 769 of the Civil Code. The decision established important precedent on distinguishing donations inter vivos from mortis causa through intent analysis.