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    Sps. Devisfruto v. Greenfell

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    Jay jogs
    The Supreme Court denied the petition of the Devisfruto Spouses. The Court found that Maxima Greenfell financed the purchase of two properties that were registered under Ruth Dizon Devisfruto's name. The Devisfruto Spouses argued that Greenfell had donated the properties to them. However, the Court determined that for a donation of money or purchase money to be valid, it must be in writing under Article 748 of the Civil Code. As the Devisfruto Spouses did not provide any written evidence of a donation, their claim that the properties were donated was invalid for failing to meet the formal requirements under the law.

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    Sps. Devisfruto v. Greenfell

    Uploaded by

    Jay jogs
    301 views2 pages
    The Supreme Court denied the petition of the Devisfruto Spouses. The Court found that Maxima Greenfell financed the purchase of two properties that were registered under Ruth Dizon Devisfruto's name. The Devisfruto Spouses argued that Greenfell had donated the properties to them. However, the Court determined that for a donation of money or purchase money to be valid, it must be in writing under Article 748 of the Civil Code. As the Devisfruto Spouses did not provide any written evidence of a donation, their claim that the properties were donated was invalid for failing to meet the formal requirements under the law.

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    SPS. DEVISFRUTO V. GREENFELL

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    The Supreme Court denied the petition of the Devisfruto Spouses. The Court found that Maxima Greenfell financed the purchase of two properties that were registered under Ruth Dizon Devisfruto's name. The Devisfruto Spouses argued that Greenfell had donated the properties to them. However, the Court determined that for a donation of money or purchase money to be valid, it must be in writing under Article 748 of the Civil Code. As the Devisfruto Spouses did not provide any written evidence of a donation, their claim that the properties were donated was invalid for failing to meet the formal requirements under the law.

    Copyright:

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

    Sps. Devisfruto v. Greenfell

    Uploaded by

    Jay jogs
    The Supreme Court denied the petition of the Devisfruto Spouses. The Court found that Maxima Greenfell financed the purchase of two properties that were registered under Ruth Dizon Devisfruto's name. The Devisfruto Spouses argued that Greenfell had donated the properties to them. However, the Court determined that for a donation of money or purchase money to be valid, it must be in writing under Article 748 of the Civil Code. As the Devisfruto Spouses did not provide any written evidence of a donation, their claim that the properties were donated was invalid for failing to meet the formal requirements under the law.

    Copyright:

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

    SPOUSES RUTH DIZON DEVISFRUTO AND ALLAN DEVISFRUTO, PETITIONERS,

    V. MAXIMA L. GREENFELL, RESPONDENT

    G.R. No. 227725, July 01, 2020

    Leonen, J. – Third Division

    NATURE OF THE ACTION:

    Petition for Review on Certiorari questioning the Decision and Resolution of the Court of
    Appeals.

    FACTS:

    Maxima Greenfell was a natural-born citizen who later became an Australian citizen.
    Prior to reacquiring Filipino citizenship, she financed the purchase of a house and 2 lots, from
    Spouses Dante and Erna Magisa. The lots were registered in the name of her niece, Ruth Dizon
    Devisfruto. Deeds of sale were executed by which the Magisa Spouses sold the properties to
    Ruth. Thereafter, the Devisfruto Spouses possessed the properties and Ruth declared herself as
    the owner, as shown in a Tax Declaration. In April 2009, after reacquiring her Philippine
    citizenship, Greenfell demanded that the properties be transferred to her name. When Ruth
    refused to comply, Greenfell filed the Complaint for Reconveyance before the Municipal Circuit
    Trial Court.

    The MTC, RTC, and CA ruled in favor of Greenfell. The Devisfruto Spouses argued that
    the properties had been given gratuitously to them. They allege that respondent gave the
    properties to Ruth because she is her favorite niece, and claim that respondent only filed a case
    after their relationship turned sour. They insist that it was not unlikely for respondent to
    gratuitously give the property to Ruth, as she has the financial capacity to assist less fortunate
    relatives.

    ISSUE:

    Whether or not the subject properties were donated to the Spouses Devisfruto.

    RULING:

    No. The Petition is DENIED.

    In Carinan v. Spouses Cueto, where it was argued that the respondent therein had
    gratuitously paid the purchase money for property as a donation, this Court noted that donations
    of purchase money must follow the formal requirements mandated by law:

    In order to sufficiently substantiate her 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. Article 748 of the New Civil Code (NCC), which applies to
    donations of money, is explicit on this point as it reads:

    Art. 748. The donation of a movable may be made orally or in writing. —

    An oral donation requires the simultaneous delivery of the thing or of the document
    representing the right donated.
    If the value of the personal property donated exceeds five thousand pesos, the donation
    and the acceptance shall be made in writing. Otherwise, the donation shall be void.

    As the Court ruled in Moreño-Lentfer v. Wolff, 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.

    Although petitioners repeatedly insisted that the purchase money for the properties was
    gratuitously given, it appears that they did not, at any stage, present evidence that this donation
    complied with the formal requirements under Article 748 of the Civil Code. Thus, this Court sees
    no reason to consider this argument any further.

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