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Central Philippines University vs C.A.

Facts:
In 1939, late Don Ramon Lopez. Sr. executed a deed of donations in favor of Central Philippines
University (CPU) of a parcel of land with the following conditions:
The land shall be exclusively use for the establishment of and use of a medical college.
CPU shall not sell, transfer or convey to any third party or any way the land.
The said land shall be called Ramon Lopez Campus
However in 1989, the respondents who are heirs of Don Ramon filed an action for annulment of
donation, re-conveyance and damages against CPU alleging that since 1939 has not complied
with the conditions of the donation and that the University negotiate with National House
Authority (NHA) to exchange the donated land with another land.
ISSUE:
Whether or not all the rights of the done are deemed lost and extinguished because of the non-
fulfillment of the conditions?

SUPREME COURT RULING:


The donation was onerous, one executed for a valuable consideration which is considered the
equivalent of the donation itself, e.g., when a donation imposes a burden equivalent to the
value of the donation. The burdens or conditions set forth in the donation were resolutory
conditions which mean the fulfillment of the conditions extinguishes the obligation. Since the
records are clear and facts are undisputed that since the execution of the deed of donation until
filing of instant action, petitioner has failed to comply with its obligation as done. CPU has slept
its obligation for unreasonable length of time so it is only just and equitable to declare the
donation ineffective.

Pwede na dili isulat: Ayaw kalimti oblicon


Under Art. 1181 of the Civil Code, in conditional obligations, the acquisition of rights, as well
as extiguishment or loss of those already acquired shall depend upon happening of the event
which constitutes the condition. Thus, when a person donated a land to another on the
condition that the order would build on the land a school. The condition imposed was not a
condition precedent or suspensive condition but a resolutory condition.
When obligations does not fix a period from its nature and circumstances it can be inferred that
the period was intended, the general rule provided in Art. 1197 of the Civil Code applies, which
provides that the court may fix the durations thereof because the fulfillment of the obligations
itself cannot be demanded until the court has fixed the period for compliance therewith and
such period has arrived.
However, this general rule cannot be applied in this case. More than a reasonable period of 50
years has been allowed for petitioner to avail of the opportunity to comply with the obligations
Art. 1191 of Civil Code, when one of the obligators cannot comply with what is incumbent
upon him, the oblige may seek rescission and the court shall decree the same unless there is
just cause authorizing the fixing of the period.

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