In Philippine taxation, the donation of real property is a "gratuitous transfer" subject to Donor’s Tax. When a single property is owned by multiple individuals (co-owners) and subsequently donated to one or more donees, the tax implications are governed by the National Internal Revenue Code (NIRC) of 1997, as amended by the TRAIN Law (Republic Act No. 10963).

Navigating the exemptions and tax credits available for multiple donors requires an understanding of the nature of co-ownership and the "per donor, per calendar year" rule.

1. The Principle of Severability in Co-ownership

Under the Civil Code of the Philippines, co-owners (such as siblings inheriting a parent’s house or spouses owning conjugal property) own an undivided interest in the property. For tax purposes, each co-owner is treated as a separate donor based on their pro-rata share of the property.

Example: If three siblings (A, B, and C) co-own a piece of land worth ₱900,000 and decide to donate it to a nephew, the Bureau of Internal Revenue (BIR) does not view this as one ₱900,000 donation. Instead, it is treated as three separate donations of ₱300,000 each.

2. The Annual Exempt Threshold (TRAIN Law)

Since January 1, 2018, the TRAIN Law has simplified donor’s tax into a flat rate of 6% on the total net gifts made during a calendar year. Crucially, it provides a significant exemption:

The ₱250,000 Annual Exemption: The first ₱250,000 of the total net gifts made by a donor within a single calendar year is exempt from donor’s tax.
Application to Multiple Donors: Because each co-owner is a separate taxpayer, each donor is entitled to their own ₱250,000 exemption.

In the example above (three siblings donating a ₱900,000 property), each sibling would apply the ₱250,000 exemption to their ₱300,000 share. Consequently, each would only pay 6% tax on the remaining ₱50,000.

3. Conjugal Property and Spousal Donations

When a husband and wife donate property belonging to their common fund (Absolute Community or Conjugal Partnership of Gains), the donation is legally considered as one-half (1/2) coming from the husband and one-half (1/2) coming from the wife.

Double Exemption: This allows a married couple to effectively donate up to ₱500,000 worth of property per year (₱250,000 each) without incurring donor's tax.
Note on Signatures: Both spouses must sign the Deed of Donation to reflect this split; otherwise, the BIR may treat it as a donation by only one spouse, potentially exhausting only one exemption.

4. Specific Exemptions under Section 101 of the NIRC

Beyond the ₱250,000 threshold, certain donations are exempt regardless of the number of donors, provided the property is donated to specific entities:

To the Government: Gifts made to or for the use of the National Government or any entity created by any of its agencies which is not conducted for profit, or to any political subdivision of the said Government.
To Educational/Charitable/Religious Institutions: Gifts in favor of an educational and/or charitable, religious, cultural or social welfare corporation, institution, accredited non-government organization, trust or philanthropic organization or research institution.
Condition: No more than 30% of said gifts shall be used by such donee for administration purposes.

5. Valuation and Documentation

To claim these exemptions correctly, the following must be observed:

Valuation: The property is valued at the Fair Market Value (FMV) as determined by the Commissioner (Zonal Value) or the FMV shown in the schedule of values fixed by the Provincial and City Assessors (Assessed Value), whichever is higher at the time of donation.
The Deed of Donation: In cases of multiple donors, the Deed of Donation should explicitly state the names of all donors and their respective interests/shares in the property to facilitate the correct calculation of individual tax liabilities.
Filing Requirements: A separate Donor’s Tax Return (BIR Form 1800) must generally be filed for each donor within thirty (30) days after the date the gift is made.

6. The "Stranger" Rule (Repealed)

Under the old law (pre-2018), donations to "strangers" were taxed at a higher rate of 30%. The TRAIN Law abolished the distinction between relatives and strangers. Now, whether the multiple donors are giving the property to a family member or a third party, the 6% flat rate and the ₱250,000 individual exemption apply uniformly.

Summary Table: Tax Impact for Multiple Donors

Scenario	Tax Treatment
Individual Donor	₱250,000 exempt; 6% on excess.
Two Co-owners (50/50)	₱500,000 total exempt (₱250k each); 6% on excess.
Spouses (Conjugal)	₱500,000 total exempt (₱250k each); 6% on excess.
Donation to Accredited NGO	Fully exempt (if admin costs < 30%), regardless of value.