Professional Documents
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GUZMAN
HELD: NO.
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.
ISSUE: Whether or not there was a donation inter
vivos