The University of Santo Tomas v. Valentin Descals

Summary

This 1918 Supreme Court case involved a dispute over a censo (ground rent) created in 1843 on a house in Intramuros in favor of University of Santo Tomas. When the house became dangerously dilapidated and was ordered demolished by municipal authorities, the University sought P2,000 damages from defendant Descals, claiming he failed to maintain the property. The Supreme Court affirmed the trial court's judgment limiting recovery to P16 (value of salvaged materials) and declaring the censo extinguished. Applying Article 1625 of the Civil Code, the Court held that the building's deterioration through natural decay over time constituted force majeure or fortuitous event, not defendant's fault, thus extinguishing the annuity obligation. The decision established important precedent regarding the extinction of real property annuities due to natural deterioration and the application of force majeure principles in civil property law.