- Petitioner
- Paulina Garcia
- Respondent
- Roberto Sañgil
- Citation
- G.R. No. 29593
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ostrand, J.
- Decided
- December 29, 1928
Summary
This case involves the validity of a donation of rice mill shares made by Alejandro Sañgil to Paulina Garcia moments before their marriage on June 13, 1923. After the spouses separated in 1925, Garcia sought dissolution of the rice mill partnership and accounting of profits, but Roberto Sañgil (manager) refused. Meanwhile, creditor Sixto Joaquin obtained judgment against Alejandro and levied execution on Garcia's donated share. The Supreme Court affirmed the lower court's ruling that the donation was valid as it occurred before marriage, not during marriage, thus Article 1334 of the Civil Code prohibiting donations between spouses during marriage was inapplicable. The donation was governed by Articles 1327-1333 as a donation by reason of marriage, making Garcia the absolute owner of the rice mill share, and the execution sale to Joaquin was void. The case establishes important precedent on the timing and validity of pre-marital donations in Philippine civil law.