Fortunata Solis v. Maxima Barroso

Summary

This case involves a donation propter nuptias made through a private document by spouses to their son and his bride-to-be in 1919. After the son's death, the surviving spouse sued to compel execution of a proper deed for her half of the donated property. The lower court applied contract law (Article 1279) and granted relief. The Supreme Court reversed, holding that donations of real property must comply with Article 633 requiring a public instrument for validity. Since the donation was made via private document, it was invalid and created no enforceable rights. The Court clarified that donations propter nuptias must follow donation law rules, not contract law, and that marriage serves as a resolutory condition rather than consideration making the donation onerous.