FACTS:

This case involves a 1,069 sq. m. lot in Bayugan, Agusan del Sur, originally owned by Felix Cosio and his wife, Felisa Cuysona. On April 21, 1959, the spouses Cosio donated the land to the South Philippine Union Mission of Seventh Day Adventist Church of Bayugan Esperanza, Agusan (SPUM-SDA Bayugan). The donation was allegedly accepted by Liberato Rayos, an elder of the church, on behalf of the donee. Twenty-one years later, on February 28, 1980, the same parcel of land was sold by the spouses Cosio to the Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM). Petitioners, claiming to be the alleged donee's successors-in-interest, asserted ownership over the property. However, respondents argued that the donee was not legally capable of receiving the donation since it had not been incorporated yet and had no juridical personality. Petitioners filed a case in the Regional Trial Court (RTC) seeking the cancellation of title and reconveyance, but the trial court ruled in favor of respondents. The Court of Appeals affirmed the RTC decision, and petitioners filed a petition for review with the Supreme Court.

ISSUES:

1. Should SDA-NEMM's ownership of the lot be upheld?

RULING:

1. Yes, SDA-NEMM's ownership of the lot covered by TCT No. 4468 should be upheld. The Court held that the alleged donation to the petitioners' alleged predecessors-in-interest in 1959 was void. At the time the donation was made, the supposed donee, SPUM-SDA Bayugan, did not exist yet and therefore had no juridical personality or capacity to accept the donation. Thus, the sale to SDA-NEMM in 1980 was considered valid and binding.

PRINCIPLES:

• Donation is an act of liberality whereby a person disposes gratuitously of a thing or right in favor of another person who accepts it.

• Ownership of a property may be transferred by tradition as a consequence of a sale.

• An appeal generally opens the entire case for review.