Case Digest: Ong vs. Ong, G.R. No 67888

Ong vs. Ong, G.R. No 67888, Oct. 8, 1985

Subject: Obligations and Contracts

FACTS

In 1976, Imelda Ong, for and in consideration of P1 and other valuable considerations, executed in favor of private respondent Sanra Maruzzo, then a minor, a Quitclaim Deed whereby she transferred, released, assigned and quitclaimed tpo Sanra her heirs and assigns, all her rights, title, interest, and application in one-half undivided portion of the parcel of land.

In 1980, Imelda Ong revoked the aforesaid quitclaim and donated the whole property to her son, Rex Jimenez.

In 1983, Sandra, through her guardian ad litem Alfredo Ong, filed with the RTC and action against petitioners for recovery of ownership/possession and nullification of the Deed of Donation over the portion belonging to her.

In 1985, respondent Sanra, through her guardian ad litem, filed and Omnibus Motion informing the SC that she had already reached the age of majority.

The petitioners claimed that the Quitclaim Deed is null and void inasmuch as it is equivalent to a Deed of Donation, acceptance of which by the done is necessary to give its validity. Since Sandra is a minor, she had no legal personality and therefore incapable of accepting the donation.

RTC ruled in favor of respondent. CA affirmed RTC’s decision and held that the Quitclaim Deed is a conveyance of property with a valid cause or consideration.

ISSUE

Whether or not the Deed of Quitclaim is equivalent to a Deed of Sale.

RULING

Yes.

Under the law (Art 1350, NCC), in onerous contracts the cause is understood to be, for each contracting party, the prestation or promise of a thing or service by the other; in remuneratory ones, the service or benefit which Is renumerated; and in contracts of pure beneficence, the mere liberality of the benefactor.

It is not unusual, however, in deeds of conveyance adhering to the Anglo-Saxon practice of stating that the consideration given is the sum of P1.00, although the actual consideration may have been much more. Moreover, assuming that said consideration of P1.00 is suspicious, this circumstance, alone, does not necessarily justify the inference that the buyers were not purchasers in good faith and for value. Neither does this inference warrant the conclusion that the sales were null and void ab initio. Indeed, bad faith and inadequacy of the monetary consideration do not render a conveyance inexistent, for the assignor's liberality may be sufficient cause for a valid contract (Article 1350, Civil Code), whereas fraud or bad faith may render either rescissible or voidable, although valid until annulled, a contract concerning an object certain entered into with a cause and with the consent of the contracting parties, as in the case at bar."