Imelda Ong, et al. vs. Alfredo Ong, et al.

A quitclaim deed conveying real property for a nominal consideration of One Peso and other valuable considerations is a valid conveyance supported by sufficient cause or consideration; the nominal or inadequate amount stated does not render the conveyance inexistent or void. Even if construed as a donation, a pure donation to a minor requires no acceptance by the minor’s legal representative.

Imelda Ong held a one-half undivided interest in a parcel of land in Makati, while Sandra Maruzzo was a minor who acquired an interest through a quitclaim deed executed by Imelda, with Alfredo Ong acting as Sandra’s representative and later as her guardian ad litem. The dispute implicated the Civil Code rules on cause or consideration in conveyances and on the acceptance of donations by minors.

On February 25, 1976, Imelda Ong executed a Quitclaim Deed in favor of Sandra Maruzzo, then a minor, for and in consideration of One Peso and other valuable considerations. By that deed, Imelda transferred, released, assigned, and forever quitclaimed to Sandra, her heirs and assigns, all her rights, title, interest, and participation in the one-half undivided portion of a parcel of land described as Lot 10-B of the subdivision plan (LRC) Psd 157841, being a portion of Lot 10, Block 18, Psd-13288, LRC (GLRC) Record No. 2029, situated in Makati, Rizal, containing an area of 125 square meters. The deed recited that the consideration was paid by Sandra through her representative, Alfredo Ong.

On November 19, 1980, Imelda revoked the Quitclaim Deed. Thereafter, on January 20, 1982, she donated the whole property to her son, Rex Ong-Jimenez. Because of these acts, Sandra, through her guardian ad litem Alfredo Ong, filed on June 20, 1983 an action with the Regional Trial Court of Makati, Metro Manila for recovery of ownership/possession and nullification of the Deed of Donation over the portion belonging to her, and for accounting.

In their responsive pleading, petitioners claimed that the Quitclaim Deed was null and void because it was equivalent to a Deed of Donation, acceptance by the donee being necessary to give it validity. They further averred that Sandra, being a minor, had no legal personality and was therefore incapable of accepting the donation. Upon admission of the documents involved, the parties filed their responsive memoranda and submitted the case for decision.

• Nature of the Quitclaim Deed: Petitioners argued that the Quitclaim Deed is null and void because it is equivalent to a Deed of Donation, and acceptance by the donee is necessary to give it validity.
• Minor’s Capacity: Petitioners maintained that Sandra Maruzzo, being a minor, had no legal personality and was therefore incapable of accepting the donation.
• Insufficient Consideration: Petitioners contended that the One Peso consideration is not a consideration at all to sustain the ruling that the Deed of Quitclaim is equivalent to a sale.
• Interpretation of the Deed: Petitioners questioned the interpretation given by the Intermediate Appellate Court to the Quitclaim Deed.

• Nature and Validity of the Quitclaim Deed: Whether the Quitclaim Deed is a valid conveyance or a donation that requires acceptance for validity.
• Sufficiency of Consideration: Whether the One Peso consideration and the other valuable considerations constitute a valid cause or consideration to sustain the conveyance.
• Acceptance by Minor Donee: Whether acceptance by the donee is necessary when the donee is a minor and the conveyance is a pure donation.
• Effect of Inadequacy of Consideration: Whether the nominal or inadequate consideration renders the conveyance void or inexistent.

• Nature and Validity of the Quitclaim Deed: The Quitclaim Deed is a valid conveyance, not an invalid donation. It is equivalent to a deed of sale supported by cause or consideration.
• Sufficiency of Consideration: Yes. The cause or consideration is not the One Peso alone but also the other valuable considerations; the deed states that consideration was given, and the presumption of sufficient cause supports it.
• Acceptance by Minor Donee: No. Even if considered a donation, acceptance by the minor’s legal representative is not required for a simple or pure donation imposing no condition.
• Effect of Inadequacy of Consideration: No. Inadequacy or nominal amount of consideration does not render the conveyance inexistent or void; liberality may be sufficient cause, and fraud or bad faith may render the contract rescissible or voidable, not inexistent.

• Nature and Validity of the Quitclaim Deed: The deed conveyed the one-half undivided portion for and in consideration of One Peso and other valuable considerations paid by Sandra through her representative, Alfredo Ong. The cause or consideration is not the One Peso alone but also the other valuable considerations. The deed is therefore a valid conveyance, and the appellate court correctly held it equivalent to a deed of sale.
• Sufficiency of Consideration: Article 1354 of the Civil Code presumes that a cause exists even if not stated, unless the debtor proves the contrary, and Section 5(r), Rule 131, Rules of Court, presumes a sufficient cause. This presumption cannot be overcome by a simple assertion of lack of consideration, especially when the contract itself states that consideration was given and is embodied in a public instrument with all formalities. The party alleging lack must prove it by preponderance of evidence in a proper action, as in Samanilla vs. Cajucom. Execution of a deed purporting to convey ownership of realty is prima facie evidence of valuable consideration, and the burden is on the party alleging lack, as in Caballero vs. Caballero. The stated One Peso is not unusual in deeds of conveyance; actual consideration may be more. Inadequacy or suspicion of the One Peso does not render the conveyance inexistent or void; liberality may be sufficient cause under Article 1350, and fraud or bad faith may render the contract rescissible or voidable, not inexistent, as in Morales Development Co., Inc. vs. CA.
• Acceptance by Minor Donee: Even if the Quitclaim Deed were a donation, Article 741 of the Civil Code requires acceptance of a donation in favor of a minor by parents or legal representatives only for onerous and conditional donations where the donation may have to assume charges or burdens under Article 726. Acceptance by a legal guardian of a simple or pure donation is not necessary. Perez vs. Calingo and Kapunan vs. Casilan and Court of Appeals held that a donation to an incapacitated donee does not need acceptance by the lawful representative if the donation contains no condition. In a simple and pure donation, formal acceptance is not important because the donor requires no right to be protected and the donee neither undertakes to do anything nor assumes any obligation. The Quitclaim Deed imposed no condition.
• Effect of Inadequacy of Consideration: Inadequacy of the monetary consideration does not render a conveyance inexistent. The assignor’s liberality may be sufficient cause for a valid contract under Article 1350. Fraud or bad faith may render the contract rescissible or voidable, but valid until annulled, where there is an object certain, a cause, and consent. Thus the nominal One Peso did not invalidate the conveyance.

• Presumption of Sufficient Cause or Consideration — A contract’s cause or consideration is presumed to exist and to be sufficient even if not stated; the party alleging lack of consideration bears the burden of proving it by preponderance of evidence in a proper action. In this case, the Quitclaim Deed stated One Peso and other valuable considerations, was reduced to a public instrument, and petitioners’ mere assertion of lack of consideration did not overcome the presumption.
• Nominal Consideration in Deeds of Conveyance — The practice of stating a nominal amount such as One Peso in a deed of conveyance is not unusual, and the actual consideration may be greater. Inadequacy or nominal nature of the stated consideration does not render the conveyance inexistent or void; the assignor’s liberality may be a sufficient cause, while fraud or bad faith may make the contract rescissible or voidable but not inexistent. The Court applied this to uphold the Quitclaim Deed.
• Prima Facie Evidence of Valuable Consideration — The execution of a deed purporting to convey ownership of realty is prima facie evidence of the existence of a valuable consideration, and the party alleging lack of consideration has the burden of proving such allegation. The Court used this to reject petitioners’ claim that the One Peso was not a consideration at all.
• Acceptance of Pure Donation to a Minor — The requirement that acceptance of a donation in favor of a minor be made by the parents or legal representatives applies only to onerous and conditional donations where the donation may have to assume charges or burdens. A simple or pure donation imposing no condition does not require acceptance by the minor’s legal representative. The Court applied this alternative holding even if the Quitclaim Deed were considered a donation.

• "Stated differently, the cause or consideration is not the One (P1.00) Peso alone but also the other valuable considerations." — This is the Court’s central interpretation of the deed, rejecting the claim that the One Peso was the sole consideration.
• "It is a legal presumption of sufficient cause or consideration supporting a contract even if such cause is not stated therein (Article 1354, New Civil Code of the Philippines.)" — This states the presumption relied upon to uphold the deed despite petitioners’ assertion of lack of consideration.
• "The execution of a deed purporting to convey ownership of a realty is in itself prima facie evidence of the existence of a valuable consideration, the party alleging lack of consideration has the burden of proving such allegation." — This allocates the burden of proof and supports the validity of the conveyance.
• "In simple and pure donation, the formal acceptance is not important for the donor requires no right to be protected and the donee neither undertakes to do anything nor assumes any obligation." — This supports the alternative holding that even if the deed were a donation, acceptance by the minor’s legal representative was unnecessary.

• Samanilla vs. Cajucom, et al., 107 Phil. 432 — Cited for the rule that lack of consideration must be shown by preponderance of evidence in a proper action to overcome the presumption of consideration.
• Caballero, et al. vs. Caballero, et al., (CA), 45 O.G. 2536 — Cited for the rule that execution of a deed purporting to convey ownership of realty is prima facie evidence of valuable consideration, with the burden on the party alleging lack.
• Perez vs. Calingo, CA-40 O.G. 53 — Cited for the rule that acceptance by a legal guardian of a simple or pure donation is not necessary.
• Kapunan vs. Casilan and Court of Appeals, 109 Phil. 889 — Cited for the rule that a donation to an incapacitated donee does not need acceptance by the lawful representative if the donation contains no condition.
• Morales Development Co., Inc. vs. CA, 27 SCRA 484 — Cited for the rule that a One Peso consideration in deeds of sale is not unusual, and inadequacy of monetary consideration does not render a conveyance inexistent; liberality may be sufficient cause, while fraud or bad faith may render the contract rescissible or voidable.

• Article 1354, Civil Code — Presumption that a cause exists even if not stated; applied to uphold the Quitclaim Deed despite the absence of a stated cause beyond the nominal amount and other valuable considerations.
• Section 5(r), Rule 131, Rules of Court — Disputable presumption that there is a sufficient cause of the contract; applied in support of the deed’s validity.
• Article 741, Civil Code — Requirement of acceptance of a donation in favor of a minor by parents or legal representatives applies only to onerous and conditional donations; applied to hold that acceptance was not required for the pure donation.
• Article 726, Civil Code — Cited in relation to onerous and conditional donations where the donation may have to assume charges or burdens; used to distinguish such donations from a simple or pure donation.
• Article 1350, Civil Code — Provides that the assignor’s liberality may be sufficient cause for a valid contract; applied to uphold the conveyance despite inadequacy of monetary consideration.

Teehankee (Chairman), Melencio-Herrera, Plana, De la Fuente, and Patajo, JJ., concurred. Gutierrez, Jr., J., concurred in the result.