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    Seventh Day Adventist

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    1) The original owners of a parcel of land, the Spouses Cosio, donated the land to the South Philippine Union Mission of Seventh Day Adventist Church – Baguyan (SPUM-SDA Bayugan). However, 20 years later the Spouses Cosio sold the same land to the Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM). 2) SPUM-SDA Bayugan did not have legal personality or capacity to accept the donation at the time because it was not yet incorporated. 3) The court upheld SDA-NEMM's ownership of the land, finding that the donation to SPUM-SDA Bay

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    Seventh Day Adventist

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    roze
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    1) The original owners of a parcel of land, the Spouses Cosio, donated the land to the South Philippine Union Mission of Seventh Day Adventist Church – Baguyan (SPUM-SDA Bayugan). However, 20 years later the Spouses Cosio sold the same land to the Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM). 2) SPUM-SDA Bayugan did not have legal personality or capacity to accept the donation at the time because it was not yet incorporated. 3) The court upheld SDA-NEMM's ownership of the land, finding that the donation to SPUM-SDA Bay

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    Seventh Day Adventist case digest

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    1) The original owners of a parcel of land, the Spouses Cosio, donated the land to the South Philippine Union Mission of Seventh Day Adventist Church – Baguyan (SPUM-SDA Bayugan). However, 20 years later the Spouses Cosio sold the same land to the Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM). 2) SPUM-SDA Bayugan did not have legal personality or capacity to accept the donation at the time because it was not yet incorporated. 3) The court upheld SDA-NEMM's ownership of the land, finding that the donation to SPUM-SDA Bay

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    41 views2 pages

    Seventh Day Adventist

    Uploaded by

    roze
    1) The original owners of a parcel of land, the Spouses Cosio, donated the land to the South Philippine Union Mission of Seventh Day Adventist Church – Baguyan (SPUM-SDA Bayugan). However, 20 years later the Spouses Cosio sold the same land to the Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM). 2) SPUM-SDA Bayugan did not have legal personality or capacity to accept the donation at the time because it was not yet incorporated. 3) The court upheld SDA-NEMM's ownership of the land, finding that the donation to SPUM-SDA Bay

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 2

    Seventh Day Adventist

    (South Philippine Union Mission of Seventh Day Adventist Church – Baguyan v Seventh
    Day Adventist Church of Northeastern Mindanao Mission)
    G.R. No. 150416. July 21, 2006
    Case Digest

    FACTS:
    Original owner of the parcel of land: Spouses Cosio
    Donee: South Philippine Union Mission of Seventh Day Adventist Church – Baguyan
    (SPUM-SDA Bayugan)
    Buyer: Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM)

    Spouses Felix Cosio and Felisa Cuysona donate a parcel of land to South Philippine
    [Union] Mission of Seventh Day Adventist Church Baguyan (SPUM-SDA Bayugan), and
    was received by Liberato Rayos, an elder of the Baguyan (SPUM-SDA Bayugan), on
    behalf of the donee.

    However, twenty years later, the spouses sold the same land to the Seventh Day
    Adventist Church of Northeastern Mindanao Mission (SDA-NEMM).

    Claiming to be the alleged donee’s successors-in-interest, petitioners asserted


    ownership over the property. This was opposed by respondents who argued that at the
    time of the donation, SPUM-SDA Bayugan could not legally be a donee because, not
    having been incorporated yet, it had no juridical personality. Neither were petitioners
    members of the local church then, hence, the donation could not have been made
    particularly to them.

    ISSUE:
    Whether or not the Seventh Day Adventist Church of Northeastern Mindanao Mission's
    ownership of the lot should be upheld.

    HELD:
    Yes. The court answered in the affirmative.

    NCC provides that one mode to acquire ownership of a property is through donation.
    Donation is an act of liberality whereby a person disposes gratuitously of a thing or right
    in favor of another person who accepts it. The donation could not have been made in
    favor of an entity yet inexistent at the time it was made. Nor could it have been accepted
    as there was yet no one to accept it.

    The deed of donation was not in favor of any informal group of SDA members but a
    supposed SPUM-SDA Bayugan (the local church) which, at the time, had neither
    juridical personality nor capacity to accept such gift. On the other hand, there is
    sufficient basis to affirm the title of SDA-NEMM, the deed of Absolute Sale and
    certificate of title in SDA-NEMM’s name.
    Thus, Seventh Day Adventist Church of Northeastern Mindanao Mission's ownership of
    the lot should be upheld. Transfer of ownership from the spouses Cosio to SDA-NEMM
    was made upon constructive delivery of the property on February 28, 1980 when the
    sale was made through a public instrument.

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