G.R. No. 206103 March 29, 2017
LYDIA LAVAREZ, ET AL., Petitioners, vs. ANGELES S. GUEVARRA, ET AL., AND THE REGISTER OF DEEDS OF LUCENA CITY, Respondents.

FACTS

Rebecca Zaballero died intestate and without issue in 1996. Her heirs, the petitioners (children of her siblings) and respondents (other nieces/nephews), disputed the distribution of her estate. Petitioners filed an action for reconveyance, partition, and nullification of documents, alleging that deeds of donation executed by Rebecca in May 1993 in favor of the respondents were invalid. They contended Rebecca lacked the requisite mental capacity to donate due to senile dementia.
The Regional Trial Court (RTC) ruled in favor of the petitioners, declaring the deeds of donation null for being tainted with vices of consent and ordering the reversion of the properties to Rebecca’s estate for partition. The Court of Appeals (CA) reversed this finding, upholding the validity of the donations. The CA held that the petitioners failed to sufficiently prove Rebecca’s incapacity, noting that advanced age and physical dependence did not equate to mental incapacity. Petitioners sought review before the Supreme Court.

ISSUE

Whether Rebecca Zaballero possessed the mental capacity to execute valid deeds of donation on May 12, 1993.

RULING

The Supreme Court granted the petition and reinstated the RTC decision, declaring the deeds of donation null and void. The Court emphasized that the burden of proof to establish the donor’s incapacity rests on the party alleging it. However, this burden was successfully discharged by the petitioners.
The legal logic centered on the evaluation of evidence regarding Rebecca’s mental state at the exact time of the donation’s execution. The Court gave conclusive weight to the expert testimony of Rebecca’s attending physician, Dr. Conde, who diagnosed her with “senile dementia” as early as 1991 and consistently until her death. This medical condition, defined as a progressive mental deterioration, directly impaired her cognitive faculties, including memory and judgment. The Court found that the CA erred in disregarding this uncontroverted expert opinion, which was based on prolonged and direct observation, in favor of the respondents’ general assertions of Rebecca’s coherence.
The Court reiterated that factual findings of the trial court, especially its assessment of witness credibility, are generally binding on appellate courts. It found no arbitrariness in the RTC’s reliance on the physician’s testimony to conclude that Rebecca could not have possessed the intelligent, free, and spontaneous consent required for a valid donation on the critical date. Therefore, the deeds were invalid for lack of contractual consent.