- Petitioner
- The Secretary of Education
- Respondent
- Heirs of Rufino Dulay, Sr.
- Citation
- G.R. No. 164748
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Callejo, Sr., J.
- Decided
- January 27, 2006
Summary
The Supreme Court affirmed the revocation of a 1981 deed of donation involving a 10,000-square-meter property donated by spouses Dulay to the Department of Education for school purposes. The Court found that DECS failed to comply with the condition to use the land for school purposes, as the property remained idle for over 16 years while DECS built its school on a different site. The Court ruled that since the donation was onerous (with conditions), it was governed by contract law rather than pure donation law, with a 10-year prescriptive period. The action was timely filed as the cause of action accrues only after expiration of reasonable time for the donee to comply with conditions. This case establishes important precedent on conditional donations and the application of prescription periods for onerous donations.