Imelda Ong v.

Alfredo Ong
Facts:
On February 25, 1976, Imelda Ong, for and in consideration of One (P1.00) and other valuable
considerations, executed in favor of private respondent, Sandra Maruzzo, then a minor, a
Quitclaim Deed1
o The Quitclaim Deed transferred, released and assigned and forever quit-claimed to Sandra,
her heirs and assigns, all her rights and title, interest, and participation in ONE HALF
undivided portion of a parcel of land in Makati
Imelda revoked the Deed and donated the whole property to her son, Rex
Sandra, through her guardian Alfredo Ong, filed with the RTC an action against petitioners for the
recovery of ownership/possession and nullification of the Deed of Donation
Petitioners claim that the Quitclaim Deed is null and void because it is equivalent to a Deed
of Donation
o Acceptance by the donee was necessary
o Sandra, being a minor, had no legal personality and was therefore incapable of
accepting the donation
The trial court rendered judgment in favor of Sandra
o The court held that the Quitclaim Deed is equivalent to a Deed of Sale, and hence
there was valid conveyance in favor of Sandra
Petitioners appealed to the IAC
o Petitioner contended that the P1.00 consideration is NOT a consideration at all to sustain
the ruling that the Quitclaim Deed is equivalent to a sale
o The IAC denied this contention and affirmed the trial court
The consideration of P1.00 was clearly stated in the deed itself
The apparent inadequacy is of no moment
It is the usual practice in deeds of conveyance to place a NOMINAL
AMOUNT although there is a more valuable consideration
Petitioner filed the instant petition
o *Sandra reached the age of majority and substituted Alfredo Ong in the case filed in the SC

Issue: Whether the IAC erred in ruling that the Quitclaim Deed is equivalent to a Deed of SaleNo

Held:
The Quitclaim Deed states that the conveyance of the undivided portion of the property was for
and in consideration of P1.00 and the other valuable considerations
o The cause or consideration is NOT THE P1.00 ALONE but also OTHER VALUABLE
CONSIDERATIONS
The Court reiterated the decision of the IAC:
o Although the cause is not stated in the contract, it is presumed that it is existing UNLESS
the debtor proves the contrary
o One of the disputable presumptions is that there is a sufficient cause of the contract
o It is a legal presumption of sufficient cause or consideration supporting a contract
even if such cause is not stated therein
This presumption CANNOT be overcome by a simple assertion of lack of
consideration
Especially when the contract itself states that consideration was given, and
the same was in a public instrument
o The alleged lack of consideration must be shown by preponderance of evidence

1
 In the case at bar, the execution of the deed purporting to convey ownership of realty is in itself a
prima facie evidence of the existence of a valuable consideration
o Thus, the party alleging lack of consideration has the burden of proving such allegation
Assuming arguendo that the Deed was a donation, Art. 741 of the CC states that the requirement of
acceptance of the donation in favor of minors by parents and guardians applies ONLY TO
ONEROUS AND CONDITIONAL DONATIONS
o Does NOT apply to SIMPLE or PURE DONATIONS
Formal acceptance is not important for the donor requires no rights to be protected
and the donee does not do anything
The Quitclaim deed does not impose any condition
The Court cited the case of Morales Development Co. v. CA:
o It is not unusual, however, in deeds of conveyance adhering to the Anglo-Saxon practice of
stating the consideration given is the sum of P1.00, although ACTUAL CONSIDERATION
MAY HAVE BEEN MUCH MORE. Moreover, assuming that said P1.00 consideration is
suspicious, this circumstance alone DOES NOT necessarily justify the inference that the
buyers were not purchasers in good faith. Neither does the inference warrant the
conclusion that the sales were null and void ab initio. BAD FAITH AND INADEQUACY OF
MONETARY CONSIDERATION DO NOT RENDER A CONVEYANCE INEXISTENT