Aguinaldo Patangan v. Heirs of Margarito Patangan

Summary

The Supreme Court denied the petition seeking to compel the heirs of Margarito Patangan to execute a deed of conveyance over disputed land based on an agreement with Aguinaldo Patangan. The Court ruled that the agreement constituted a donation of immovable property which failed to comply with mandatory Civil Code requirements - it must be in a public document and properly accepted by the donee. Since these absolute formalities were not met, the agreement was void and inexistent. Additionally, the Court held that stipulations preventing sale to third parties for an indefinite period constitute undue restrictions on property ownership rights and are void as perpetual restrictions. The decision affirmed the validity of the subsequent sale to Spouses Arado and established important precedent on donation formalities and property transfer restrictions.