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Catalan vs. Basa (Digest)

This case involves a dispute over property that Feliciano Catalan donated to his sister Mercedes in 1951. The plaintiff alleges the donation was void because Feliciano suffered from schizophrenia and was therefore incompetent. However, the courts found the evidence insufficient to overcome the presumption that Feliciano was competent when he made the donation. While Feliciano had been diagnosed with schizophrenia in 1948, this does not necessarily mean he lost competence over his property. The plaintiff also did not question Feliciano's competence regarding other transactions, so he is presumed to have remained competent. The donation to Mercedes was therefore valid.

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1K views2 pages

Catalan vs. Basa (Digest)

This case involves a dispute over property that Feliciano Catalan donated to his sister Mercedes in 1951. The plaintiff alleges the donation was void because Feliciano suffered from schizophrenia and was therefore incompetent. However, the courts found the evidence insufficient to overcome the presumption that Feliciano was competent when he made the donation. While Feliciano had been diagnosed with schizophrenia in 1948, this does not necessarily mean he lost competence over his property. The plaintiff also did not question Feliciano's competence regarding other transactions, so he is presumed to have remained competent. The donation to Mercedes was therefore valid.

Uploaded by

Tini Guanio
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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CATALAN vs.

BASA
GR No. 159567 – July 31, 2007
Puno

SUBJECT: Insanity; schizoprenia

FACTS:
 On Oct. 20, 1948, Feliciano Catalan was discharged from active military service. The
board of Medical officers of the Department of Veteran Affairs found that he was unfit to
render military service due to, among others, his schizophrenic reaction.
 On Sept. 28, 1949, Feliciano married Corazon Cerezo.
 On June 16, 1951, a document was executed, titled “Absolute Deed of Donation,”
wherein Feliciano allegedly donated to his sister Mercedes Catalan ½ of a certain real
property. The donation was registered and a new tax declaration was issued to Mercedes.
 On Dec. 11, 1953, People’s Bank & Trust Company filed special proceedings before the
CFI to declare Feliciano incompetent, where the TC ruled in favor the bank and
appointed it as Feliciano’s guardian. (PBTC was renamed and now known as BPI)
 On Nov. 22, 1978, Feliciano & Corazon Cerezo donated 2 lots of their property to their
son.
 On March 26, 1979, Mercedes sold the property in issue in favor of her children Delia
and Jesus Basa.
 On June 24, 1983, Feliciano & Corazon donate another lot to their children Alex,
Librada, and Zenaida Catalan.
 On Feb. 14, 1983, Feliciano & Corazon donate another lot to Eulogio & Florida Catalan.
 On April 1, 1997, BPO, acting as Feliciano’s guardian, filed a case for Declaration of
nullity of Documents, Recovery of Possession & Ownership, against respondents. It
alleged that the Deed of Absolute Donation to Mercedes was void ab initio, as Feliciano
was not of sound mind and was therefore incapable of giving valid consent.

RTC: dismissed the complaint. Found that the evidence presented was insufficient to overcome
the presumption that Feliciano was sane and competent at the time he executed the DoD in favor
of Mercedes Catalan.
CA: affirmed the RTC decision.

ISSUE: WON Feliciano’s incompetency renders the deed of donation he executed void.

HELD: The findings of the RTC and CA are affirmed.


Donation is an act of liberality whereby a person disposes gratuitously a thing or right in favor of
another, who accepts it. Like any other contract, an agreement of parties is essential. Consent of
contract presupposes the following requisites:
(1) it should be intelligent or with an exact notion of the matter to which it refers;
(2) it should be free; and
(3) it should be spontaneous.
The parties intention must be clear and the attendance of a vice of consent, like any contract,
renders the donation voidable.
In order for donation of property to be valid, what is crucial is the donor’s capacity to give
consent at the time of the donation. Certainly, there lies no doubt in the fact that insanity
impinges on consent freely given. However, the burden of proving such incapacity rests upon the
person who alleges it; if no sufficient proof to this effect is presented, capacity will be presumed.

In the case at bar, the evidence president by the petitioners was insufficient to overcome the
presumption that Feliciano was competent when he donated the property in question to
Mercedes.

The findings by the Board of Medical Officers of the Dept. of Veteran Affairs cannot prove
Feliciano’s incompetence. A study of the nature of schizophrenia will show that Feliciano could
still be presumed capable of attending to his property rights. Administration of the correct
medicine helps the patient. Medications reduce delusions, hallucinations, and incoherent
thoughts and reduce or eliminate chances of relapse.

From these, it can be deduced that a person suffering from schizophrenia does not necessarily
loses his competence to intelligently dispose his property. By merely alleging the existence of
schizophrenia, petitioners failed to show substantial proof that at the date of the donation,
Feliciano Catalan had lost total control of his mental faculties.

It is interesting to note that the petitioners questioned Feliciano’s capacity at the time he donated
the property, yet did not see fit to question his mental competence when he entered into a
contract of marriage with Corazon Cerezo or when he executed deeds of donation of his other
properties in their favor. The presumption that Feliciano remained competent to execute
contracts, despite his illness, is bolstered by the existence of these other contracts. Competency
and freedom from undue influence, shown to have existed in the other acts done or contracts
executed, are presumed to continue until the contrary is shown.

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