Republic of the Philippines Represented By the Register of Deeds of Pasay City v. Court of Appeals (Special Former 3Rd Division)

Summary

This case involved a dispute over whether properties allegedly donated by Elizabeth Hankins to her longtime domestic helper Amada Solano could be subject to escheat proceedings. After Hankins died in 1985, the Republic successfully escheated her entire estate, including the disputed properties, to Pasay City in 1989. Seven years later, Solano claimed to have found the misplaced deeds of donation and sought to annul the escheat judgment through the Court of Appeals. While the appellate court initially gave due course to the annulment petition, the Supreme Court reversed this decision, emphasizing that escheat is an incident of state sovereignty and that the 5-year statutory period for filing claims in escheat proceedings had long expired. The Court held that without clear and convincing proof of valid donation presented during the original escheat proceedings, the properties properly remained part of the decedent's estate and were validly escheated to the state.