Gregorio Escario v. Antero Regis

Summary

This landmark property rights case involved a dispute between Gregorio Escario and the heirs of Fausta Regis over three parcels of land in Cebu. Escario obtained a composition title from the Spanish government in 1892, then executed a gift inter vivos to Fausta Regis in 1893 while childless. After Fausta's death, her heirs claimed ownership based on the gift. The Supreme Court reversed the trial court's decision favoring the heirs, holding that Escario's composition title carried a strong legal presumption of validity that could not be overcome by parol evidence alone. The Court ruled that the gift was properly rescinded by operation of law when Escario subsequently had legitimate children, as provided by the Civil Code. This decision established important precedents regarding the validity and presumptive effect of government-issued land titles and the automatic rescission of gifts inter vivos upon the donor having children.