Felix Danguilan v. Intermediate Appellate Court

Summary

This case involves a property ownership dispute between Felix Danguilan and Apolonia Melad over two lots previously owned by Domingo Melad. Respondent claimed purchase via a 1943 deed of sale, while petitioner claimed donation through private instruments in 1941 and 1943. The trial court favored petitioner based on possession and credibility. The Intermediate Appellate Court reversed, finding the private donation instruments invalid for lacking public form. The Supreme Court reinstated the trial court decision, ruling that the donations were onerous (conditioned on care and burial services) and thus valid even in private form under the Manalo doctrine. The Court also found the deed of sale suspicious and emphasized that petitioner maintained actual possession throughout. The decision reinforced the principle that onerous donations differ from gratuitous ones in formal requirements and that actual possession creates a presumption of ownership when competing claims are weak.