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

The spouses Felix Cosio and Felisa Cuysona donated a parcel of land to the South Philippine Union Mission of the Seventh Day Adventist Church in the past. However, 20 years later, they sold the same land to the Seventh Day Adventist Church of Northeastern Mindanao Mission. The Seventh Day Adventist Conference Church of Southern Philippines claimed ownership as successors-in-interest of the original donee. However, the court ruled in favor of the Seventh Day Adventist Church of Northeastern Mindanao Mission, as the original donee did not have legal personality or capacity to accept the donation at the time since it had not been incorporated yet. The donation and subsequent sale were both upheld.

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61 views1 page

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

The spouses Felix Cosio and Felisa Cuysona donated a parcel of land to the South Philippine Union Mission of the Seventh Day Adventist Church in the past. However, 20 years later, they sold the same land to the Seventh Day Adventist Church of Northeastern Mindanao Mission. The Seventh Day Adventist Conference Church of Southern Philippines claimed ownership as successors-in-interest of the original donee. However, the court ruled in favor of the Seventh Day Adventist Church of Northeastern Mindanao Mission, as the original donee did not have legal personality or capacity to accept the donation at the time since it had not been incorporated yet. The donation and subsequent sale were both upheld.

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jenny martinez
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Seventh Day Adventist Conference Church vs.

Northeastern
Mindanao Mission of Seventh Day Adventist, GR 150416, 7/21/06
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 donees 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.

Posted by Jesselle Maminta at 2:00 AM No comments:

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