- Petitioner
- Government Service Insurance System (Gsis)
- Respondent
- The Province of Tarlac
- Citation
- G.R. No. 157860
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ynares-Santiago, J.
- Decided
- December 1, 2003
Summary
The Supreme Court resolved a dispute over the validity of a land donation from Province of Tarlac to GSIS for construction of a government office. The Court of Appeals had declared the donation void for failure to obtain required appraised valuation under Section 381 of the Local Government Code. However, the Supreme Court reversed this decision, holding that the absence of such valuation does not automatically void the donation since neither the Civil Code nor Local Government Code expressly declares such transfers void. The Court emphasized the presumption of validity of duly executed contracts and the principle that perfected contracts cannot be unilaterally revoked. This case establishes important precedent regarding local government property transfers and the interplay between administrative requirements and contract validity principles.
Intellegal Wiki · Key Holding
Granted the petition and reversed the CA, holding that a local government's donation of land lacking the appraised valuation required by Section 381 of the Local Government Code is not thereby void, since it is not among the void contracts enumerated in Article 1409 and no law expressly declares such a transfer void; a perfected contract enjoys a presumption of validity and cannot be unilaterally revoked.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.