- Petitioner
- Arsenia Ecaldre
- Respondent
- Spouses Romeo Ecaldre
- Citation
- G.R. No. 250214
- Court
- Supreme Court
- Division
- Second Division
- Decided
- September 7, 2020
Summary
This case involves a family property dispute between siblings Arsenia and Romeo Ecaldre over real properties originally donated by Anastacia Dominguez to Romeo in 1978. Arsenia claimed co-ownership based on Romeo's 1999 affidavit, but both the Court of Appeals and Supreme Court rejected this claim. The Supreme Court ruled that the original 1978 donation clearly named only Romeo as the sole donee, with no indication of intended co-ownership. Furthermore, Romeo's subsequent affidavit constituted a donation of immovable property that required Arsenia's formal acceptance under Article 749 of the Civil Code, which was lacking. The decision reinforces the strict formal requirements for valid donations of immovable property and the importance of clear language in donation instruments.
Intellegal Wiki · Key Holding
An affidavit donating immovable property requires the donee's acceptance in the same or a separate public document under Article 749; co-ownership is not presumed absent an expressed intent to create it.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.