FACTS:

The case involves a dispute over the ownership of a land granted to Fermina Lopez by the Bureau of Lands. Fermina executed a Deed of Self-Adjudication and Transfer of Rights over the land in favor of Amelita Sola, who agreed to assume all the obligations, duties, and conditions imposed upon Fermina. Amelita paid the full amount for the lot and was issued a Certificate of Title.

However, Castorio Alvarico, the natural father of Amelita, claimed that Fermina had donated the land to him before the transfer to Amelita took place. Castorio argued that his donation invalidated the earlier transfer to Amelita.

The Regional Trial Court ruled in favor of Castorio and ordered the reconveyance of the land. However, on appeal, the Court of Appeals reversed the decision and dismissed the complaint filed by Castorio.

Castorio then filed a petition for review before the Supreme Court, seeking the reversal of the Court of Appeals decision.

ISSUES:

1. Whether the deed of donation executed by Fermina in favor of petitioner is valid.

2. Whether Amelita is the lawful owner of the property.

RULING:

1. The Court of Appeals erred in declaring that the deed of donation in favor of petitioner was only embodied in a private document. The deed of donation was notarized and therefore, is a public document.

2. The principle that the registration of the sales patent constitutes the operative act that would convey ownership of the land to the applicant is not applicable in this case. The controversy between petitioner and respondent does not involve the registration of a sales patent.

PRINCIPLES:

• The validity of a deed of donation may be determined based on the formality and requirements of a valid donation under the Civil Code.

• The registration of a sales patent is not always the operative act that would convey ownership of the land, especially in cases where the dispute does not involve the registration of a sales patent.