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By: Bie
GR No. 132964
Topic: Donation
Date: February 18, 2000
Facts
David Rey Guzman, a natural-born American citizen, is the son of the spouses Simeon Guzman (naturalized American)
and Helen Meyers Guzman (American citizen). In 1968, Simeon died leaving to his heirs, Helen and David, an estate
consisting of several parcels of land in Bulacan.
In 1970, Helen and David executed a Deed of Extrajudicial Settlement of the Estate, dividing and adjudicating to
themselves all of the property, and registered it to the RD a year after.
In 1981, Helen executed a Deed of Quitclaim, assigning, transferring and conveying her share of the properties to
David. But since it was not registered, she executed another Deed of Quitclaim to confirm the first.
In 1994, Atty. Batongbacal wrote the OSG andfurnished it with documents showing that Davids ownership of of the
estate was defective. He argued that Art. XII of the Constitution only allows Filipinos to acquire private lands in the
country. The only instances when a foreigner may acquire private property are by hereditary succession and if he was
formerly a natural-born citizen who lost his Filipino citizenship. Moreover, it contends that the Deeds of Quitclaim
executed by Helen were really donations inter vivos.
Republic filed with RTC a Petition for Escheat praying that of Davids interest be forfeited in its favor. RTC
dismissed. CA affirmed.