Case Digest (G.R. No. 133705) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 24, 1977, C-J Yulo & Sons, Inc. (Donor) executed a deed of donation conveying a 41,117-square-meter parcel in Canlubang, Calamba, Laguna, to Roman Catholic Bishop of San Pablo, Inc. (Donee) under Transfer Certificate of Title No. T-82803, later replaced by TCT No. T-91348. The deed, accepted by the Donee, imposed several onerous conditions: construction and maintenance of a home for the aged and infirm without religious discrimination; establishment of a 15-meter green belt; agricultural use of surplus land for the institution’s support; permissible commercial leasing only with the Donor’s prior written consent; annual masses for the Yulo family; and an express reversion clause in case of breach. Beginning in 1980, the Donee entered into three successive leases of portions of the donated land—to Martin Gomez for sugar cane cultivation, to Jose Bostre as a ranch, and to Rudy Caballes for cattle fattening—each without the Donor’s written consent. On September 20, 1990 Case Digest (G.R. No. 133705) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Donation and conditions
- On September 24, 1977, C-J Yulo & Sons, Inc. (Donor) executed a Deed of Donation in favor of the Roman Catholic Bishop of San Pablo, Inc. (Donee) covering a 41,117 sqm parcel in Canlubang, Calamba, Laguna (TCT No. T-82803).
- The deed imposed material conditions:
- Establish and maintain a home for the aged and infirm, with a 15-m green belt and an area for agriculture.
- Lease unused areas for socially acceptable commercial purposes only with Donor’s prior written consent; rental proceeds to support the home.
- Celebrate annual masses for the Yulo family.
- Failure to comply would cause automatic reversion to Donor in trust for another charitable grantee.
- Post-donation developments and litigation
- Donee registered the donation (TCT No. T-91348) and, without prior written consent, entered three successive leases (circa 1980 to Gomez for sugar cane; 1986 to Bostre for ranch; to Caballes for cattle) to raise funds for home construction.
- On September 20, 1990, Donor revoked the donation for material breach; Donee refused to reconvey title.
- On November 19, 1990, Donor filed suit in RTC Calamba for revocation and reconveyance.
- On December 22, 1995, the RTC granted revocation; on December 19, 1997, the CA reversed, upholding the donation; April 30, 1998 motion for reconsideration denied.
- Donor elevated the case to the Supreme Court via a petition for review on certiorari.
Issues:
- Breach and revocation
- Whether the Donee’s unauthorized leases and delay in constructing the home constitute substantial breaches warranting valid revocation of an onerous donation.
- Prescription
- Whether Donor’s action is barred by prescription under Article 1144 (10 years) or Article 764 (4 years) of the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)