Short answer. Yes. Article 86 of the Family Code lets a donor revoke a donation by reason of marriage when the donee has committed an act of ingratitude as specified by the Civil Code's provisions on donations in general. A donation propter nuptias is not exempt from that ground simply because it was tied to a wedding.
What the law says
A donation by reason of marriage may be revoked by the donor in the following cases
Family Code, Article 86 — Revoking Donations by Reason of Marriage. Read the full provision →
What the law says
When the donee has committed an act of ingratitude as specified by the provisions of the Civil Code on donations in general.
Family Code, Article 86 — Revoking Donations by Reason of Marriage. Read the full provision →
Donations by reason of marriage can still be revoked
A wedding gift that qualifies as a donation by reason of marriage — a donation propter nuptias — is not beyond revocation just because it was made in connection with your wedding. A donation by reason of marriage may be revoked by the donor in the following cases. Article 86 lists six specific cases, and the last one covers exactly the situation you describe.
Ingratitude is its own, separate ground
Article 86 states the ground plainly: When the donee has committed an act of ingratitude as specified by the provisions of the Civil Code on donations in general. Rather than defining ingratitude on its own terms, the Family Code adopts whatever the Civil Code already recognizes as an act of ingratitude for donations generally, and applies that same standard to a wedding gift.
Why the Family Code borrows the Civil Code's standard
By pointing to the Civil Code's provisions on donations in general, Article 86 avoids creating a separate, wedding-specific definition of ingratitude. Whatever counts as an act of ingratitude serious enough to justify revoking an ordinary donation counts here too — a wedding gift is not held to a looser standard, nor a stricter one, simply because of the occasion it was given for or the relationship between donor and donee.
This is one of several grounds under Article 86
Ingratitude sits alongside other grounds Article 86 recognizes for revoking a donation by reason of marriage — the marriage not taking place, marriage without required parental consent, annulment where the donee acted in bad faith, legal separation where the donee is the guilty spouse, and a resolutory condition being fulfilled. Your situation falls specifically under the ingratitude ground, independent of whether any of the others also apply, and each ground can support revocation on its own without needing to establish the rest.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Heirs of Cesario Velasquez, et al. vs. Court of Appeals, et al, G.R. No. 126996, February 15, 2000 — read the decision on LawPhil →