Facts:

The case involves two petitions for review on certiorari filed by the Roman Catholic Archbishop of Manila, the Roman Catholic Bishop of Imus, and spouses Florencio and Soledad C. Ignao against the Court of Appeals and the estate of deceased spouses Eusebio de Castro and Martina Rieta, represented by Marina Rieta Granados and Theresa Rieta Tolentino. The events leading to the case began on November 29, 1984, when the private respondents filed a complaint for nullification of a deed of donation, rescission of contract, and reconveyance of real property with damages against the petitioners in the Regional Trial Court of Imus, Cavite, which was docketed as Civil Case No. 095-84. The complaint alleged that on August 23, 1930, the deceased spouses Eusebio de Castro and Martina Rieta executed a deed of donation in favor of the Roman Catholic Archbishop of Manila for a parcel of land in Kawit, Cavite, with a stipulation that the donee could not sell or dispose of the property for 100...

Facts:

1. Parties Involved:

   • Petitioners: The Roman Catholic Archbishop of Manila, The Roman Catholic Bishop of Imus, and the spouses Florencio Ignao and Soledad C. Ignao.
   • Respondents: The Estate of deceased spouses Eusebio de Castro and Martina Rieta, represented by Marina Rieta Granados and Theresa Rieta Tolentino.

2. Background of the Case:

   • On August 23, 1930, the spouses Eusebio de Castro and Martina Rieta executed a deed of donation in favor of the Roman Catholic Archbishop of Manila, covering a parcel of land (Lot No. 626, Cadastral Survey of Kawit) in Kawit, Cavite.
   • The deed of donation contained a condition that the donee shall not dispose or sell the property within 100 years from the execution of the deed. Violation of this condition would render the deed null and void, and the property would revert to the estate of the donors.

3. Alleged Violation:

   • On June 30, 1980, the Roman Catholic Bishop of Imus (to whom the administration of the property was transferred in 1962) executed a deed of absolute sale of the property in favor of the spouses Florencio and Soledad Ignao for P114,000.00.
   • Transfer Certificate of Title No. 115990 was issued in the name of the Ignao spouses on November 15, 1980.

4. Legal Proceedings:

   • On November 29, 1984, the respondents filed a complaint for nullification of the deed of donation, rescission of the contract, and reconveyance of the property with damages.
   • The petitioners filed motions to dismiss, arguing that the respondents had no legal capacity to sue, the complaint stated no cause of action, and the cause of action had prescribed.
   • The Regional Trial Court (RTC) dismissed the complaint on the ground of prescription.
   • The Court of Appeals reversed the RTC's decision, reinstating the case and remanding it for further proceedings.

Issue:

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Ruling:

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Ratio:

1. Automatic Reversion:

   • The deed of donation provided for automatic reversion of the property upon violation of the condition, making a judicial declaration of nullity unnecessary. This stipulation was valid and enforceable, and the general rules on prescription for written contracts applied.

2. Invalidity of the Condition:

   • The condition prohibiting the sale of the property for 100 years was an unreasonable restriction on the rights of ownership and was contrary to public policy. Such a condition was deemed invalid under Article 727 of the Civil Code, which considers impossible or illegal conditions as not imposed.

3. No Cause of Action:

   • Since the condition in the deed of donation was invalid, the sale of the property did not violate the deed, and the respondents had no cause of action against the petitioners. The Court emphasized that the prohibition against alienation must not be perpetual or for an unreasonable period of time.

4. Judicial Review of Unassigned Errors:

   • The Court held that it had the authority to review matters not assigned as errors on appeal if necessary for a just decision. In this case, the validity of the condition in the deed of donation was closely related to the assigned errors and was necessary for the resolution of the case.

Conclusion:

The Supreme Court set aside the decision of the Court of Appeals and dismissed Civil Case No. 095-84, holding that the respondents had no cause of action against the petitioners due to the invalidity of the condition in the deed of donation.