Case Digest (G.R. No. 194199)
Facts:
In Province of Camarines Sur v. Bodega Glassware, the Province of Camarines Sur (petitioner), represented by Governor Luis Raymund F. Villafuerte, Jr., owns a 600 sqm parcel in Peñafrancia, Naga City (OCT No. 22). On September 28, 1966, then-Governor Apolonio G. Maleniza executed a Deed of Donation Inter Vivos in favor of the Camarines Sur Teachers’ Association, Inc. (CASTEA), incorporating an automatic revocation clause: the land was to be used solely for association offices, not mortgaged or encumbered, and must host construction within one year, lest the donation be “automatically revoked.” CASTEA complied initially but, on September 1, 1995, leased the property to respondent Bodega Glassware for 20 years without constructing the association building. In July 2005, the Provincial Legal Officer questioned Bodega’s title; petitioner thereafter merely tolerated Bodega’s occupation until October 4, 2007, when it formally demanded vacation and, on October 14, 2007, executed a DeedCase Digest (G.R. No. 194199)
Facts:
- Parties and Property
- Petitioner: Province of Camarines Sur, owner of a 600 sqm parcel in Peñafrancia, Naga City (OCT No. 22).
- Donee: Camarines Sur Teachers’ Association, Inc. (CASTEA), received donation inter vivos by Deed of Donation dated September 28, 1966, containing an automatic revocation clause.
- Subsequent Lease and Procedural History
- On September 1, 1995, CASTEA leased the donated portion to Bodega Glassware for 20 years; Bodega took possession.
- July 2005: Provincial Legal Officer requested Bodega’s proof of title; none presented; petitioner tolerated continued possession.
- October 4, 2007: Petitioner demanded Bodega vacate; October 14, 2007: petitioner executed Deed of Revocation citing breach of donation conditions; Bodega refused to vacate.
- March 13, 2008: Petitioner filed unlawful detainer (MTC Naga City, Branch 2); December 11, 2008: MTC ruled for petitioner—ordered ejectment and P15,000/month compensation.
- May 13, 2009: RTC, Branch 26 (Naga City) reversed MTC—dismissed action for lack of proof.
- May 31, 2010: CA denied petitioner’s appeal—affirmed RTC, ruling donor must file reconveyance and petition prescribed.
- March 22, 2017: Supreme Court granted certiorari under Rule 45 to resolve competing possession claims and effect of automatic revocation clause.
Issues:
- Which party—petitioner or Bodega—has the better right to actual physical possession?
- What is the legal effect of the automatic revocation clause in the Deed of Donation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)