G.R. No. 77425 - Roman Catholic Archbishop vs. Court of Appeals

In 1930, spouses Eusebio de Castro and Martina Rieta executed a deed of donation in favor of the Roman Catholic Archbishop of Manila covering Lot No. 626, Kawit, Cavite (964 sqm), with a resolutory condition prohibiting disposition or sale for 100 years, “ipso facto null and void” upon breach.
On April 26, 1962, administration of all Archdiocese of Manila properties in Cavite was transferred to the Roman Catholic Bishop of Imus.

On June 30, 1980, while still within the 100-year prohibition, the Bishop of Imus executed a deed of absolute sale of the donated lot to spouses Florencio and Soledad C. Ignao for ₱114,000.00; Transfer Certificate of Title No. 115990 was issued November 15, 1980.
On November 29, 1984, private respondents (heirs of the original donors) filed Civil Case No. 095-84 in the RTC, Imus, Cavite for:

December 1984–January 1985: petitioners filed motions to dismiss for lack of capacity, absence of cause of action, and prescription.
January 31, 1985: RTC Branch XX granted dismissal on the ground that the cause of action had prescribed.
Private respondents appealed to the Court of Appeals, which on December 23, 1986 set aside the RTC order, reinstated the case, and remanded it for further proceedings. Reconsideration was denied February 6, 1987.
Petitioners filed petitions for review on certiorari with the Supreme Court (G.R. Nos. 77425 and 77450), challenging the CA’s prescription ruling.

Whether the action for revocation of the deed of donation under Article 764, Civil Code, is barred by the four-year prescription period.
Whether the main action for reconveyance is also dismissed when the rescission action is barred.

Whether the 100-year prohibition on alienation constitutes an enforceable condition.
Whether such condition violates public policy as an undue restriction on ownership rights.