G.R. No. 112127 - Central Philippine University vs. Court of Appeals

In 1939, Don Ramon Lopez, Sr., then trustee of Central Philippine College (now Central Philippine University or CPU), executed a deed of donation of Lot No. 3174-B-1 (Transfer Certificate of Title No. T-3910-A) in favor of CPU.
The deed contained these annotations as conditions:

Exclusive use of the land for establishing and operating a medical college with all its buildings.
Prohibition against selling, transferring, conveying, or encumbering the land to any third party.
Naming the site “RAMON LOPEZ CAMPUS,” erecting a cornerstone with that name, and dedicating net income to a “RAMON LOPEZ CAMPUS FUND” for campus improvements and building erection.

On May 31, 1989, private respondents (heirs of Don Ramon Lopez, Sr.) filed an action for annulment of donation, reconveyance, and damages, alleging CPU’s long-standing noncompliance with the deed’s conditions and an attempted exchange deal with the National Housing Authority.
CPU answered, contending that (a) the action was barred by prescription, (b) it never breached any condition, and (c) it never sold or encumbered the property.
On May 31, 1991, the Regional Trial Court (Iloilo City, Br. 34) ruled CPU failed to comply with the conditions, declared the donation null and void, and ordered reconveyance to the heirs.
On June 18, 1993, the Court of Appeals reversed, holding that the annotations were resolutory conditions whose breach would revoke the donation, but since no period for compliance was fixed, CPU could not yet be deemed noncompliant; the case was remanded to set the time for fulfilling the first condition.
CPU petitioned the Supreme Court for review on certiorari, challenging the Court of Appeals’ characterization of the conditions, its treatment of prescription, and the propriety of remanding to fix a compliance period.

Whether the annotations in the certificate of title constitute onerous obligations and resolutory conditions, breach of which renders the donation revocable.
Whether private respondents’ action for revocation and reconveyance is barred by prescription.
Whether it was proper to remand the case to fix the period within which CPU should establish the medical college.