Juliana Abragan v. Rita G. de Centenera

Summary

This case involves a dispute over the validity of deeds of gift executed by Andres Garchitorena to his natural daughter and her mother. The Supreme Court affirmed that unnotarized deeds of gift have no legal effect under Philippine law, as they must be in public document form and accepted by donees during the donor's lifetime. While the donor's heir later ratified some gifts, this could not retroactively perfect the original donations but created an estoppel against the heir. The case establishes important precedent on the formal requirements for valid donations of real property and the limitations of post-death ratification by heirs. The Court emphasized that such ratification cannot prejudice estate administration or creditors' rights.