Rowena Patenia-Kinatac-An v. Enriqueta Patenia-Decena

Summary

Family dispute over validity of parents' donation of 9,600-sq m property to some children, with other siblings claiming forgery and impairment of inheritance rights. Petitioners challenged deed execution and notarization defects, arguing donation was void for failure to comply with Civil Code formalities. All three court levels rejected the challenge. Supreme Court held that 2002 donation was governed by Revised Administrative Code which did not require parties to sign notarial register, distinguishing from 2004 notarial rules. Court emphasized donations of immovables must comply with Article 749 solemnity requirements but found compliance satisfied. Decision clarifies temporal application of notarial rules and reaffirms strict compliance requirements for real property donations while protecting vested rights from retroactive procedural changes.