Case Digest (G.R. No. 232675)
Facts:
Municipality of Dasmarinas v. Dr. Paulo C. Campos, G.R. Nos. 232675 and 233078, July 17, 2019, Supreme Court Third Division, Reyes, A., Jr., J. The petitions for review under Rule 45 challenged the Court of Appeals' Decision (Nov. 10, 2016) and Resolution (July 3, 2017) in CA‑G.R. CV No. 100259, which affirmed the Regional Trial Court (RTC) of Imus, Cavite, Branch 22, Decision (Mar. 16, 2011) dismissing the complaint of the Municipality of Dasmarinas and the National Housing Authority (NHA) for lack of merit.Dr. Paulo C. Campos was the registered owner of several contiguous parcels in Dasmarinas, Cavite, and on July 28, 1976 executed a Deed of Donation (first deed) in favor of the NHA covering 12,798 sq. m., conditioned on the construction of a 36‑meter‑wide access road from Highway 17 to the Dasmarinas Resettlement Project; the deed also contained a reservation permitting the donor to use the area if the donee delayed development. The NHA constructed only a 20‑meter road, claiming traffic conditions justified reserving the remaining 16 m for future widening and asserting the unpaved portion remained part of the access road.
On June 13, 1993 the NHA, allegedly pursuant to P.D. No. 957, Sec. 31, executed a second Deed of Donation conveying roads (aggregate 219,765.60 sq. m.) to the Municipality of Dasmarinas; that second deed did not reproduce the 36‑m specification. Because the NHA did not complete the 36‑m road and later transferred the property to the Municipality, Dr. Campos filed an action for Revocation of Donation on November 13, 2001. Dr. Campos died in 2007 and his children substituted as plaintiffs.
The RTC (Branch 22) rendered judgment on March 16, 2011, partially granting revocation: it declared the 1976 deed partially revoked as to the area not included in the 20‑m road, nullified the 1993 deed to the same extent, ordered reconveyance and turnover of possession to Dr. Campos' heirs, but denied moral damages and attorney’s fees. The RTC denied the NHA’s motion for reconsideration (Aug. 12, 2011). The petitioners appealed to the Court of Appeals.
The Court of Appeals (Nov. 10, 2016) denied the petitioners’ appeal and affirmed the RTC: it treated the 1976 donation as onerous and governed by the law on contracts (Civil Code, Art. 1144), found prescription accrued only upon the 1993 donation, concluded the NHA’s failure to build the full 36‑m road was a substantial breach, and held P.D. No. 957 did not justify the subsequent donation because the Resettlement Project is not a subdivision or condominium under that statute. The CA denied reconsideration (July 3, 2017). ...(Subscriber-Only)
Issues:
- Procedural: Did the action to revoke the Deed of Donation prescribe or is it barred by laches?
- Substantive: Did the Court of Appeals err in affirming the RTC that the NHA materially breached the Deed of Donation, authorizing partial revocation (the unused 16 m), and did the petitioners offer valid justification ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)