SEVENTH DAY ADVENTIST CONFERENCE CHURCH OF SOUTHERN PHILIPPINES, INC., and/or represented by MANASSEH C. ARRANGUEZ, BRIGIDO P.

GULAY, FRANCISCO M. LUCENARA, DIONICES O. TIPGOS, LORESTO C. MURILLON, ISRAEL C. NINAL, GEORGE G. SOMOSOT, JESSIE T. ORBISO, LORETO PAEL and JOEL BACUBAS, petitioners vs. NORTHEASTERN MINDANAO MISSION OF SEVENTH DAY ADVENTIST, INC., and/or represented by JOSUE A. LAYON, WENDELL M. SERRANO, FLORANTE P. TY and JETHRO CALAHAT and/or SEVENTH DAY ADVENTIST CHURCH [OF] NORTHEASTERN MINDANAO MISSION, Respondents G.R. No. 150416 July 21, 2006 FACTS: This case involves two supposed transfers of the lot previously owned by the spouses Cosio. The first transfer was a donation to petitioners alleged predecessors-in-interest in 1959 while the second transfer was through a contract of sale to respondents in 1980. A TCT was later issued in the name of respondents. Claiming to be the alleged donees successors-in-interest, petitioners filed a case for cancellation of title, quieting of ownership and possession, declaratory relief and reconveyance with prayer for preliminary injunction and damages against respondents. Respondents, on the other hand, argued that at the time of the donation, petitioners predecessors-in-interest has no juridical personality to accept the donation because it was not yet incorporated. Moreover, petitioners were not members of the local church then. The RTC upheld the sale in favor of respondents, which was affirmed by the Court of Appeals, on the ground that all the essential requisites of a contract were present and it also applied the indefeasibility of title. ISSUE: Whether or not the donation was void. HELD: Yes, the donation was void because the local church had neither juridical personality nor capacity to accept such gift since it was inexistent at the time it was made. The Court denied petitioners contention that there exists a de facto corporation. While there existed the old Corporation Law (Act 1459), a law under which the local church could have been organized, petitioners admitted that they did not even attempt to incorporate at that time nor the organization was registered at the Securities and Exchange Commission. Hence, petitioners obviously could not have claimed succession to an entity that never came to exist. And since some of the representatives of petitioner Seventh Day Adventist Conference Church of Southern Philippines, Inc. were not even members of the local church then, it necessarily follows that they could not even claim that the donation was particularly for them.