Seventh Day Adventist Conference Church of Southern Philippines vs. North Eastern Mindanao Mission of Seventh Day Adventist, Inc. (496 SCRA 215)

FACTS:
Spouses Felix Cosio and Felisa Cuysona donate a parcel of land to South Philippine [Union] Mission of Seventh Day Adventist Church, and was received by Liberato Rayos, an elder of the Seventh Day Adventist Church, 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.

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:
Should the Seventh Day Adventist Church of Northeastern Mindanao Mission's ownership of the lot be upheld?

HELD:
We answer in the affirmative.

Donation is undeniably one of the modes of acquiring ownership of real property. Likewise, ownership of a property may be transferred by tradition as a consequence of a sale.

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.

(With questions regarding de facto corporation and law of sales.)

Petition Denied.