Carinan v. Spouses Cueto, [G.R. No. 198636] Case Digest

 

Carinan v. Spouses Cueto,

G.R. No. 198636

 

Facts:

Esperanza and her husband, Jose Carinan acquired from Ventura the rights over a parcel of land formerly covered by under the name of GSIS. Esperanza sought financial assistance from her brother, Gavino for the payment of the said parcel of land. The respondents then paid from their conjugal savings Esperanza’s total obligation of ₱785,680.37 under the subject deed of assignment. Respondents alleged that Esperanza and Jazer undertook to execute a Deed of Absolute Sale in favor of the respondents once the title over the subject property was transferred to their names. When Esperanza and Jazer failed to comply despite efforts for an amicable settlement, the respondents filed with the RTC Biñan, Laguna the subject complaint for specific performance with damages.

Esperanza believed that Gavino paid her outstanding balance with the GSIS out of sheer generosity and pity upon her. She denied having borrowed the respondents’ money because given her financial standing, she knew that she could not afford to pay it back. RTC rendered judgment in favor of herein respondent. CA affirmed the rulings of RTC.

 

Issue:

Whether or not there is a Donation or help extended by respondents to Esperanza.

 

Held:

No.

 

Ratio:

In order to sufficiently substantiate Petitioners’ claim that the money paid by the respondents was actually a donation, Esperanza should have also submitted in court a copy of their written contract evincing such agreement.

A donation must comply with the mandatory formal requirements set forth by law for its validity. When the subject of donation is purchase money, Article 748 of the NCC is applicable. Accordingly, the donation of money as well as its acceptance should be in writing. Otherwise, the donation is invalid for non-compliance with the formal requisites prescribed by law.