Case Digest (G.R. No. 199666)
Facts:
In Province of Camarines Sur v. Camarines Sur Teachers and Employees Association, Inc., G.R. No. 199666, decided on October 7, 2019, the Province of Camarines Sur, represented by Governor Luis Raymund F. Villafuerte, Jr., owned a 600-square-meter parcel covered by OCT No. 22 in Barangay Peñafrancia, Naga City. On September 28, 1966, through a Deed of Donation Inter Vivos, then‐Governor Apolonio G. Maleniza donated this portion to the Camarines Sur Teachers and Employees Association, Inc. (CASTEA) under three key conditions: use solely for constructing offices for specified teachers’ associations; commence construction within one year; and not sell, mortgage, or encumber the property, with an automatic revocation clause upon non-compliance. In 1995, CASTEA leased part of the constructed building to Bodega Glassware for twenty years. On October 14, 2007, Governor Villafuerte issued a Deed of Revocation, allegedly for that lease. On February 13, 2008, the Province filed an unlawfulCase Digest (G.R. No. 199666)
Facts:
- Background of Donation
- The Province of Camarines Sur owned a 600 sqm parcel in Brgy. Peñafrancia, Naga City, covered by OCT No. 22.
- On September 28, 1966, Governor Apolonio G. Maleniza executed a Deed of Donation Inter Vivos transferring the 600 sqm to CASTEA.
- Conditions of Donation
- Use: CASTEA was to use the land solely for constructing and owning an office building for CASTEA, the Naga City Teachers’ Association, and the Camarines Sur High School Alumni Association.
- Restrictions and Term: CASTEA shall not sell, mortgage, or encumber the donated property; construction must commence within one year or the donation is “automatically revoked and voided.”
- Alleged Breach and Revocation
- CASTEA constructed the building within the one-year period. In 1995, it leased a portion to Bodega Glassware for 20 years, using rents for members’ mutual aid and death benefits.
- On October 14, 2007, the Province executed a Deed of Revocation citing the lease as an encumbrance and demanded that CASTEA vacate.
- Judicial Proceedings
- MTCC Br. 1 (March 12, 2009): Ruled for the Province, ordering CASTEA to vacate the 600 sqm and pay ₱20,000 monthly compensation from November 2007.
- RTC Branch 26 (August 10, 2009): Reversed MTCC, dismissed the unlawful detainer for lack of evidence, held revocation requires court action, and found the action prescribed.
- CA, Eleventh Division (March 16, 2011): Granted the Province’s Rule 65 petition, reversed the RTC, reinstated MTCC; held a lease is an encumbrance voiding the donation; prescription does not run against the State.
- SC (October 7, 2019): Under Rule 45 (G.R. No. 199666), reversed the CA, reinstated the RTC Decision and Order with modification, and awarded nominal damages.
Issues:
- Whether the CA erred in reversing the RTC and reinstating the MTCC Decision.
- Whether CASTEA’s 20-year lease constituted an encumbrance voiding the donation and triggering automatic revocation.
- Whether prescription barred the Province’s recovery action.
- Whether the CA committed inconsistency in separate appeals on the same property.
- Whether the CA misinterpreted the Deed of Donation and applicable Civil Code provisions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)