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Secretary of Education vs. Heirs of Dulay, Sr. (G.R. No. 164748, January 27, 2006)

 Facts

  • Rufino Dulay, Sr. and his wife, Ignacia Vicente, donated a 10,000 square meter portion of their land to the Department of Education and Culture (DECS), now the Department of Education (DepEd).
  • The deed of donation included a condition: the land was to be used for school purposes, specifically for the construction of a building for the Rizal National High School.
  • The DECS/DepEd failed to construct the school building, and the land remained unused for many years.
  • The heirs of Rufino Dulay, Sr. filed a case to revoke the donation due to this breach of condition.

Issues

  • Whether the donation was subject to a condition that the DECS/DepEd was required to fulfill.
  • Whether the failure of the DECS/DepEd to use the land for its intended purpose constituted a breach of condition, justifying the revocation of the donation.

Ruling

  • The Supreme Court ruled in favor of the heirs of Rufino Dulay, Sr.
  • The Court held that the donation was made with an explicit resolutory condition – the use of the land for school purposes.
  • The Court found that the DECS/DepEd failed to fulfill its obligation under the donation, making the revocation valid.
  • The DECS/DepEd was ordered to execute a deed of reconveyance, returning the land to the Dulay heirs.

Significance

The case highlights these important legal principles:

  • Donations with Conditions: Donations of property can have conditions attached. If the donee fails to comply with these conditions, the donation may be revoked.
  • Resolutory Conditions: A resolutory condition is a provision that, if breached, results in the automatic termination of a contract or agreement.
  • Obligations of Donees: When accepting a donation with conditions, the donee has a legal obligation to fulfill those conditions.

    Key dates
    • August 3, 1981: The spouses Rufino Dulay and Ignacia Vicente execute the deed of donation, granting the land to the Department of Education and Culture (DECS).
    • April 13, 1983: Transfer Certificate of Title (TCT) No. T-143337 is issued, covering the donated portion of the land.
    • August 19, 1994: The Dulay spouses send a letter to the DECS Secretary requesting the return of the property as it remained unused.
    • August 28, 1994: Barangay Council of Rizal, Santiago City, issues Resolution No. 39 recognizing the donors' right to redeem the land due to DECS's failure to use it as intended.
    • August 31, 1997: The heirs of Rufino Dulay, Sr. file the case for the revocation of the donation and cancellation of TCT before the RTC in Santiago City.
    • January 27, 2006: The Supreme Court issues the final decision in the case, affirming the revocation of the deed of donation.
    Location: Davao City, Davao del Sur, Philippines

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