Case Digest (G.R. No. 112127)
Facts:
Central Philippine University v. Court of Appeals, Remedios Franco, Francisco N. Lopez, Cecilia P. Vda. de Lopez, Redan Lopez and Remarene Lopez, G.R. No. 112127, July 17, 1995, the Supreme Court First Division, Bellosillo, J., writing for the Court.In 1939 Don Ramon Lopez, Sr. executed a deed of donation conveying a parcel (Lot No. 3174‑B‑1, Psd‑1144) to Central Philippine University (CPU). The deed imposed specific burdens on CPU: the land was to be used exclusively to establish and operate a medical college with buildings; CPU could not sell, transfer or encumber the land; the campus was to bear the donor’s name and any net income was to be devoted to campus improvements. The title to the lot was annotated to reflect those obligations.
On 31 May 1989 the heirs of Don Ramon Lopez, Sr. (private respondents) sued CPU for annulment of donation, reconveyance and damages, alleging CPU had not complied with the deed’s conditions and had negotiated an exchange of the property with the National Housing Authority. CPU answered that the action was prescribed and that it had not violated the conditions.
The Regional Trial Court, Branch 34, Iloilo City, rendered judgment on 31 May 1991 declaring the donation null and void for noncompliance and directing CPU to reconvey the property to the heirs. CPU appealed to the Court of Appeals. On 18 June 1993 the Court of Appeals reversed, treating the annotations as onerous, resolutory conditions whose breach would render the donation revocable, but concluding the first condition (establishment of a medical school) contained no fixed period for compliance; it remanded to the trial court to determine the time within which CPU must comply.
CPU filed a petition for review on certiorari to the Supreme Court under Rule 45 seeking reversal of the Court of Appeals’ rulings (that the annotations were onerous/resolutory, that prescription n...(Subscriber-Only)
Issues:
- Is the action of the heirs to annul the donation and seek reconveyance barred by prescription?
- Were the annotations/“conditions” in the donor’s deed onerous obligations and resolutory conditions such that noncompliance would render the donation revocable?
- Was remanding the case to the trial court to fix the period for compliance with the donat...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)