Case Digest (G.R. No. 197115)
Facts:
Republic of the Philippines, represented by the Secretary of Agriculture, v. Federico Daclan, Josefina Collado and her husband Federico Daclan, Teodoro Daclan and Minviluz Daclan as surviving heirs of deceased Jose Daclan, G.R. Nos. 197115 and 197267, March 23, 2015, Supreme Court Second Division, Del Castillo, J., writing for the Court. The petitions for review on certiorari attack the Court of Appeals’ January 25, 2011 Decision in CA-G.R. CV No. 90014 and its May 30, 2011 Resolution denying reconsideration; the petitions were consolidated by the Supreme Court.In May 1972 several members of the Daclan family (the donors) executed four Deeds of Donation conveying parcels in Barrio Nazareno, Agoo, La Union, to the Republic of the Philippines (donee) for the specific purpose of establishing the Agoo Breeding Station. The deeds contained identical conditions: (1) the lands were to be used solely as a breeding station and not for other purposes without prior consent of the donors or their heirs; and (2) in case of non-use, abandonment or cessation of the activities of the Bureau of Animal Industry (BAI), possession and ownership would automatically revert to the donors and improvements would become theirs.
After the enactment of the Local Government Code of 1991, devolution transferred certain DA/BAI functions, including operation of the breeding station, to the Province of La Union; the province thereafter operated the station. At some point approximately 1.5 hectares within the larger donated area became occupied by the La Union Medical Center (LUMC). In September 2003 the donors demanded return of their lands, alleging cessation/abandonment of the breeding station and asserting the automatic reversion clause.
On March 28, 2005 the Daclans filed Civil Case No. A-2363 for specific performance against the Republic and the Province in Branch 32, Regional Trial Court (Agoo RTC). After an ocular inspection and trial, the Agoo RTC on July 31, 2007 dismissed the complaint, finding that the breeding station continued to operate under the Province after devolution and that the transfer by operation of law did not vitiate the donations. The Daclans appealed to the Court of Appeals.
The Court of Appeals, however, on January 25, 2011 set aside the RTC decision only insofar as it concerned the 1.5-hectare portion occupied by the LUMC, concluding that that portion was no longer used for the purpose of the donation and therefore reverted to the do...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly hold that the Republic (and/or the Province) violated the deeds of donation and properly order reversion of donated land used by the La Union Medical Center?
- Did the Court of Appeals err in its treatment of the broader claim of the Daclans that the donations should revert in whole because the breeding station ceased operations or because the transfer to...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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