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    Central Philippine University V Court of Appeals DIGEST

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    invictusinc
    Don Ramon Lopez Sr. donated land to Central Philippine University (CPU) in 1939 for the establishment of a medical college, with conditions that the land be used exclusively for the college and not be sold or transferred. In 1989, Lopez's heirs filed a case claiming CPU failed to comply with the conditions and negotiated to exchange the land. The lower court sided with the heirs. The Court of Appeals modified the decision, finding that over 50 years was a reasonable time for CPU to comply but it failed to do so. As the donation was subject to a resolutory condition and CPU did not fulfill it within a reasonable time period, the donation was revoked and the heirs were entitled to reconveyance of the land.

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    Central Philippine University V Court of Appeals DIGEST

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    invictusinc
    223 views2 pages
    Don Ramon Lopez Sr. donated land to Central Philippine University (CPU) in 1939 for the establishment of a medical college, with conditions that the land be used exclusively for the college and not be sold or transferred. In 1989, Lopez's heirs filed a case claiming CPU failed to comply with the conditions and negotiated to exchange the land. The lower court sided with the heirs. The Court of Appeals modified the decision, finding that over 50 years was a reasonable time for CPU to comply but it failed to do so. As the donation was subject to a resolutory condition and CPU did not fulfill it within a reasonable time period, the donation was revoked and the heirs were entitled to reconveyance of the land.

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    Central Philippine University v Court of Appeals DIGEST

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    Central Philippine University v Court of Appeals DIGEST

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    Don Ramon Lopez Sr. donated land to Central Philippine University (CPU) in 1939 for the establishment of a medical college, with conditions that the land be used exclusively for the college and not be sold or transferred. In 1989, Lopez's heirs filed a case claiming CPU failed to comply with the conditions and negotiated to exchange the land. The lower court sided with the heirs. The Court of Appeals modified the decision, finding that over 50 years was a reasonable time for CPU to comply but it failed to do so. As the donation was subject to a resolutory condition and CPU did not fulfill it within a reasonable time period, the donation was revoked and the heirs were entitled to reconveyance of the land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    223 views2 pages

    Central Philippine University V Court of Appeals DIGEST

    Uploaded by

    invictusinc
    Don Ramon Lopez Sr. donated land to Central Philippine University (CPU) in 1939 for the establishment of a medical college, with conditions that the land be used exclusively for the college and not be sold or transferred. In 1989, Lopez's heirs filed a case claiming CPU failed to comply with the conditions and negotiated to exchange the land. The lower court sided with the heirs. The Court of Appeals modified the decision, finding that over 50 years was a reasonable time for CPU to comply but it failed to do so. As the donation was subject to a resolutory condition and CPU did not fulfill it within a reasonable time period, the donation was revoked and the heirs were entitled to reconveyance of the land.

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    © All Rights Reserved
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    CENTRAL PHIL UNIV. vs.

    Court of Appeals 246 SCRA 511


    FACTS:
    1. CPU: (1939) Don Ramon Lopez Sr. executed a deed of donation
    Conditions of the donation:
    a) Land should be utilized exclusively for the establishment & use of medical college.
    b) College shall not sell transfer or convey to any 3rd party.
    c)
    Land shall be called Ramon Lopez Campus
    d) Income from that land shall be put in Ramon Lopez Campus Fund for improvement
    of the facility.
    2. HEIRS (LOPEZ): (1989) filed an action for annulment of donation, reconveyance &
    damages:
    a) Non-compliance with the conditions.
    b) Negotiation with the NHA to exchange the donated property with another land.
    *CPU argued:
    right to file action has prescribed
    no violation because did not use property
    *Lower Court sided with LOPEZ HEIRS.
    ISSUE:
    1. WON CPU failed to comply conditions given there was no fixed period? YES
    2. WON there is a need to fix the period for compliance of the condition? NO
    HELD:
    RTC ILOILO DECISION REINSTATED
    CA DECISION MODIFIED
    RECONVEYANCE TO LOPEZ HEIRS WITH COSTS
    1. RESOLUTORY CONDITION: upon fulfillment, terminates an enforceable obligation.
    a. Rights are lost once the condition is fulfilled.
    b. Entitles parties to resort back to original positions.
    c. Takes effect if either parties do not comply with his/her engagements (in which
    complaining party may sue for dissolution of contract with damages)
    2. ARTICLE 1181: CONDITIONAL OBLIGATIONS
    Acquisition of rights, extinguishment/loss of acquired, shall depend on happening event
    that constitutes the condition.
    a. Donating land to another on the condition that the latter would build upon the land a
    school is RESOLUTORY IN CONDITION. The donation had to be valid before the fulfillment
    of the condition. If there was no fulfillment with the condition such as what obtains in the
    instant case, the donation may be revoked and all rights the donee may have acquired
    shall be lost and extinguished.
    b. More than a reasonable period of fifty (50) years has already been allowed petitioner
    to avail of the opportunity to comply with the condition even if it be burdensome, to
    make the donation in its favor forever valid. But, unfortunately, it failed to do so. Hence,
    there is no more need to fix the duration of a term of the obligation when such procedure
    would be a mere technicality and formality and would serve no purpose than to delay or
    lead to an unnecessary and expensive multiplication of suits.
    c. Petitioner has slept on its obligation for an unreasonable length of time. Hence, it is
    only just and equitable now to declare the subject donation already ineffective and, for
    all purposes, revoked so that petitioner as donee should now return the donated property
    to the heirs of the donor, private respondents herein, by means of reconveyance.
    d. RECONVEYANCE: property held by a trustee/mortgage is returned to its owner on his
    request.
    3. ARTICLE 1197: OBLIGATIONS WITH NO FIXED PERIOD
    GENERAL RULE: Period can be inferred from its nature or circumstances.
    Court can fix the duration because the fulfillment of the obligation itself cannot be
    demanded until after the court has fixed the period for compliance.

    a. CASE AT HAND: General rule cannot be applied in this case considering the different
    set of circumstances existing more than a reasonable period of 50 years has already
    been allowed to petitioner to avail of the opportunity to comply but unfortunately, it
    failed to do so.
    b. Hence, there is no need to fix a period when such procedure would be a mere
    technicality & formality & would serve no purpose than to delay or load to unnecessary
    and expensive multiplication of suits.

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