No Gift of Checks Endorsed in Blank

The issuance of two checks by the decedent payable to himself and endorsed in blank was insufficient to establish gifts to the depositor of the checks when there was no evidence of the relationship between the decedent and the depositor, no evidence as to the delivery of the checks, and no evidence of donative intent, and a constructive trust was imposed on the balance of the funds remaining after the depositor had used some of the funds to pay for the decedent’s household expenses and home health care. In re: Estate of Joseph M. Marchione, Deceased, 566 EDA 2024 (Pa. Super. 11/18/2024) (non-precedential).

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