All crimes which offend the donor show ingratitude and are causes for revocation of donation.


Pedro Calapine was the registered owner of a parcel of land. He executed a deed of donation inter vivos of ½ of the land to his niece, Helen Doria. Subsequently, he executed another deed of donation inter vivos ceding the other ½ of the property to Helen Doria. Helen Doria donated a protion of the lot (157 sqm) to the Calauan Christian Reformed Church. Helen Doria sold and conveyed the remaining portion save some 700 meters for his residence. Pedro Calapine sought to annul the sale and donation to eduarte and CCRC on the ground that the deed of donation was a forgery and that Doria was unworthy of his liberality claiming ingratitude (commission of offense against the person, honor or property of donor [par. 1])


W/N the falsification of public document committed by Doria is an act of ingratitude against Calapine (considering that falsification is a crime against public interest)?


In commentaries of Tolentino, it is said that “all crimes which offend the donor show ingratitude and are causes of revocation.” Petitioner attempted to categorize the offenses according to their classification under the RPC by deleting the first sentence. However, this is unwarranted considering that illegal detention, threats and coercion are considered crimes against the person of the donor despite the fact that they are classified as crimes against personal liberty and security under the RPC.

Note: Eduarte and the Church still won although the donation was deemed by the Court to be revocable. The Court applied the CHAIN OF TITLE THEORY because the lands were registered lands and it has already passed from the forger (Doria) to innocent purchasers for value (Eduarte, et al.).

EDUARTE V. CA- Revocation of Donation