Lydia Sumipat v. Brigido Banga

Summary

This Supreme Court case involved the validity of a property transfer deed executed by Lauro Sumipat in favor of his five illegitimate children. The conjugal properties were transferred through a deed signed by both Lauro and his illiterate wife Placida in 1983. The Regional Trial Court upheld the deed's validity, while the Court of Appeals partially annulled it regarding Placida's conjugal share due to vitiated consent. The Supreme Court declared the entire deed absolutely null and void on two grounds: failure to comply with Civil Code requirements for donations of immovable property (no proper acceptance by donees and no donor's tax compliance), and complete absence of Placida's consent rather than merely vitiated consent. The Court emphasized that actions to declare void contracts do not prescribe, and ordered cancellation of titles issued to the illegitimate children and reinstatement of the original titles. The case establishes important precedents on donation requirements, consent in property transfers, and the distinction between voidable and void contracts.