Roman Catholic Archbishop of Manila v. Court of Appeals
REITERATIONFacts
1. The Antecedents: This case concerns a donation of land made on August 23, 1930, by the spouses Eusebio de Castro and Martina Rieta to the Roman Catholic Archbishop of Manila. A condition in the deed stipulated that the property could not be disposed of or sold for one hundred (100) years, otherwise the deed would be ipso facto null and void, and the property would revert to the donors' estate. In 1962, administration of such properties in Cavite was allegedly transferred to the Roman Catholic Bishop of Imus. On June 30, 1980, within the 100-year prohibition period, the Bishop of Imus sold the property to spouses Florencio and Soledad C. Ignao. 2. Procedural History: The Estate of the deceased spouses Eusebio de Castro and Martina Rieta, represented by Marina Rieta Granados and Theresa Rieta Tolentino, filed a complaint for nullification of the deed of donation, rescission of contract, and reconveyance of property with damages against the Roman Catholic Archbishop of Manila, the Roman Catholic Bishop of Imus, and the spouses Ignao. The Regional Trial Court (RTC) dismissed the complaint, finding the cause of action had prescribed. The private respondents appealed to the Court of Appeals (CA), which reversed the RTC's decision, holding that the action had not prescribed and remanding the case for further proceedings. The CA denied the petitioners' motions for reconsideration. 3. The Petition: Two petitions for review on certiorari were filed with the Supreme Court by the Roman Catholic Bishop of Imus (G.R. No. 77425) and the spouses Ignao (G.R. No. 77450). The petitioners argue that the private respondents' cause of action had prescribed. The Supreme Court, however, found that the 100-year prohibition against alienation in the deed of donation was an unreasonable restriction contrary to public policy and thus void under Article 727 of the Civil Code, rendering the condition as if it were not imposed. Consequently, the sale to the Ignaos did not violate the donation. The Court ruled that while the action was not prescribed, there was no cause of action against the petitioners, leading to the dismissal of the case.
Issue(s)
Whether the action for revocation of the deed of donation has prescribed. Whether the prohibition against alienation for one hundred (100) years in the deed of donation is valid. Whether the private respondents have a valid cause of action against the petitioners.
Ruling
The Supreme Court set aside the judgment of the Court of Appeals and rendered a new judgment dismissing Civil Case No. 095-84. The Court ruled that while the action may not have prescribed, the private respondents have no cause of action because the condition prohibiting alienation for one hundred years is void as it is contrary to public policy.
Ratio Decidendi
On the issue of prescription: The Court held that Article 764 of the Civil Code, which provides a four-year prescriptive period for revocation of donations due to non-compliance with conditions, is not applicable in this case. This is because the deed of donation expressly stipulated for automatic revocation (ipso facto null and void) upon violation of the condition. The Court cited jurisprudence holding that a judicial action for rescission is not necessary when the contract itself provides for automatic cancellation upon breach, and that such stipulations are valid as long as they are not contrary to law, morals, good customs, public order, or public policy. The Court reasoned that in such cases, the action to enforce the contract prescribes in ten (10) years under Article 1144(1) of the Civil Code, and the Court of Appeals correctly ruled that the action had not yet prescribed. On the validity of the prohibition against alienation: The Court declared that the one-hundred-year prohibition against alienation in the deed of donation constitutes an undue restriction on the rights of ownership and is contrary to public policy. The Court explained that while a donor may impose conditions, these must not be contrary to law, morals, good customs, public order, or public policy. The prohibition against alienation for such an extended period is an unreasonable emasculation of an integral attribute of ownership. The Court analogously cited Articles 494 and 870 of the Civil Code, which limit prohibitions against partition or inalienability to twenty years, to support the view that a century-long prohibition is unreasonable. Therefore, the Court held that the condition is illegal or impossible within the contemplation of Article 727 of the Civil Code and shall be considered as not imposed. On the existence of a cause of action: Based on the invalidity of the one-hundred-year prohibition, the Court found that the sale of the property by the Roman Catholic Bishop of Imus to the Ignao spouses did not violate any valid condition in the deed of donation. Consequently, the private respondents' action to nullify the deed of donation and for reconveyance, which was premised on this alleged violation, lacked a valid cause of action. The Court emphasized that it has the authority to pass upon and resolve issues, even if not specifically assigned as errors, if their consideration is necessary for a just decision, especially when they are ineluctably related to assigned errors and the records permit resolution without need for further evidence.
Main Doctrine
A condition in a deed of donation prohibiting alienation of the property for an unreasonably long period, such as one hundred years, is contrary to public policy and considered as an illegal or impossible condition under Article 727 of the Civil Code, and thus shall be deemed as not imposed. Consequently, a sale of the donated property in violation of such an invalid condition does not constitute a breach of the donation, and an action to nullify the deed of donation based on such a violation lacks cause of action.