Title
Ibonilla vs. Province of Cebu
Case
G.R. No. 97463
Decision Date
Jun 26, 1992
In 1960, Cebu donated land to a school with reversion conditions. After the school's conversion, Cebu demanded its return, claiming the donation void. Petitioners opposed but lacked legal standing; the Supreme Court upheld lower courts, ruling the MOA resolved the dispute.

Case Digest (G.R. No. 97463)

Facts:

Jesus M. Ibonilla, et al., G.R. No. 97463. June 26, 1992, the Supreme Court First Division, Grino‑Aquino, J., writing for the Court.

The petitioners are groups of officials, faculty, employees, parents and school organizations connected with the Cebu (Sudlon) Agricultural School; the respondents are the Province of Cebu, the Cebu State College of Science & Technology (CSCST) (formerly Sudlon Agricultural School/Cebu Agricultural School), its Board of Trustees and members, and the Court of Appeals as named in the caption.

In 1952 the Province granted use and usufruct of forty parcels of land to the Cebu (Sudlon) Agricultural School. On March 18, 1960 the Province executed a Deed of Donation conveying the lots to the School subject to two conditions: (1) if the School ceased to operate ownership would revert to the Province, and (2) the School could not alienate, lease or encumber the properties. Under B.P. Blg. 412 (consolidation of vocational schools), the Cebu (Sudlon) Agricultural School became an extension of the Cebu State College of Agriculture in 1983.

On November 18, 1988 the Province demanded reconveyance, asserting the donation was void ab initio because the Cebu (Sudlon) Agricultural School lacked legal personality to be a donee. Petitioners opposed rescission and filed a complaint for quieting of title over the forty lots. The Province answered, maintaining the donation was null and asked for reconveyance, stating plans to use the lots for judicial residences, an NBI rehabilitation center and other government offices.

On February 1, 1989 the Province (represented by Governor Emilio M.R. Osmeña) and CSCST (represented by Secretary Lourdes R. Quisumbing) executed a Memorandum of Agreement allocating the subject parcels: nineteen lots to the Province, twenty‑three lots to the school, and reserving Lot No. 1033 (TCT No. 21411) for a national government center and DECS regional office. The MOA was ratified by the Sangguniang Panlalawigan and by the school's Board of Trustees. On March 10, 1989 the Province moved to dismiss the quieting action as moot and academic in view of the MOA; petitioners refused to withdraw the suit.

On November 8, 1989 the Regional Trial Court of Cebu City dismissed the complaint, holding the plaintiffs were not real parties in interest. The Court of Appeals, in CA‑G.R. CV No. 24536, affirm...(Pro-only)

Issues:

  • Are the petitioners real parties in interest with standing to prosecute a complaint for quieting of title?
  • Did the Memorandum of Agreement between the Province of Cebu and the Cebu State College of Science & Technology render the controversy moot or otherwise resolve the di...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.