Case Summary (G.R. No. 194199)
Key Dates
• Donation executed: September 28, 1966
• Lease to Bodega: September 1, 1995 (20-year term)
• First legal demand: July 2005
• Final demand and revocation deed: October 4 & 14, 2007
• Unlawful detainer filed: March 13, 2008
• MTC decision: December 11, 2008
• RTC reversal: May 13, 2009
• CA affirmation: May 31, 2010; Reconsideration denied October 12, 2010
• SC decision: March 22, 2017
Applicable Law
• 1987 Philippine Constitution (judicial power, due process)
• Civil Code of the Philippines (Arts. 428, 732, 764, 1144, 1147, 1306)
• Rules of Court: Rule 45 (certiorari), Rule 70 (unlawful detainer)
• Jurisprudence on automatic revocation (De Luna v. Abrigo; University of the Philippines v. De los Angeles; Roman Catholic Archbishop of Manila v. CA; Dolar; Zamboanga Barter)
Factual Background
The Province donated 600 sq.m. to CASTEA in 1966 with three conditions—including exclusive use for association offices, prohibition against sale or encumbrance, and commencement of construction within one year—plus an automatic revocation clause. CASTEA complied initially but breached by leasing the land to Bodega in 1995.
Procedural History
After informal tolerance of Bodega’s occupancy, the Province formally demanded vacation in October 2007 and revoked the donation under the automatic clause. It filed unlawful detainer in March 2008. The MTC ruled for the Province (Dec. 2008), the RTC reversed (May 2009), and the CA affirmed the RTC (May 2010). The Province then secured SC review under Rule 45.
Issue
Which party holds the rightful de facto possession: the Province as donor asserting automatic reversion upon condition breach, or Bodega as lessee under an unauthorized lease?
Automatic Revocation Clause
Under Article 1306 and settled jurisprudence, an automatic revocation or rescission clause in an onerous donation takes effect immediately upon breach, without judicial declaration, though the donee may later challenge its propriety. CASTEA’s lease breached two conditions, triggering automatic reversion of title and ownership to the Province.
Prescription of Actions
Article 764’s four-year period to annul a donation does not apply where revocation is self-executing. No ten-year reconveyance action is required. The sole pertinent prescriptive period for ejectment is one year from last demand under Rule 70, Sec. 1. The Province filed within four months.
Right to Possession in Unlawful Detainer
An unlawful detainer action addresses only actual possession. Having validly considered the donation revoked a
...continue readingCase Syllabus (G.R. No. 194199)
The Case
- Verified petition for review on certiorari under Rule 45, Rules of Court.
- Filed by the Province of Camarines Sur, represented by Governor Luis Raymund F. Villafuerte, Jr.
- Challenges Court of Appeals (CA) Decision of May 31, 2010 and Resolution of October 12, 2010.
- CA had affirmed the RTC of Naga City’s reversal of the MTC ejectment ruling in favor of petitioner.
- Central dispute: rightful physical possession of a 600 sq m parcel in Peñafrancia, Naga City.
Facts
- Petitioner owns the parcel under Original Certificate of Title No. 22.
- September 28, 1966: Donated ~600 sq m to Camarines Sur Teachers’ Association, Inc. (CASTEA) via Deed of Donation Inter Vivos.
- Deed’s automatic revocation clause required:
• Use solely for CASTEA’s office building within one year;
• No sale, mortgage, or encumbrance;
• Breach renders the donation automatically revoked. - CASTEA accepted and complied, then on August 15, 1995 leased the property to Bodega Glassware for 20 years (Sept 1, 1995–Sept 15, 2015); Bodega took possession on Sept 1, 1995.
- July 2005: Petitioner’s Provincial Legal Officer requested proof of Bodega’s title; none produced; petitioner tolerated occupancy.
- October 4, 2007: Letter demanding vacation; October 14, 2007: Deed of Revocation executed by Governor Villafuerte, invoking automatic revocation due to CASTEA’s lease.
- CASTEA never contested the revocation.
- March 13, 2008: Petitioner filed unlawful detainer seeking possession and P15,000/month compensation from October 2007.
Procedural History
- MTC Naga City (Dec 11, 2008): Granted ejectment; ordered Bodega to vacate and pay P15,000/month.
- RTC Naga City, Branch 26 (May 13, 2009): Reversed MTC; dismissed complaint for failure of proof.
- CA (May 31, 2010): Affirmed RTC; hel