- Petitioner
- Province of Camarines Sur
- Respondent
- Bodega Glassware
- Citation
- G.R. No. 194199
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Jardeleza, J.
- Decided
- March 22, 2017
Summary
The Province of Camarines Sur donated land to CASTEA in 1966 with conditions including prohibition against sale, mortgage, or encumbrance, and an automatic revocation clause. When CASTEA leased the property to Bodega Glassware in 1995, the Province claimed violation of donation conditions and revoked the donation in 2007, then filed unlawful detainer against Bodega in 2008. The Supreme Court ruled that automatic revocation clauses in donations are valid and effective without judicial intervention when conditions are breached. Since CASTEA violated the donation conditions by leasing to Bodega, the donation was automatically revoked, and the property reverted to the Province. The Court distinguished between automatic revocation (no judicial action needed) and contested revocation (judicial determination of propriety required). The Province's ejectment action was timely filed within one year of the last demand and was entitled to succeed based on its ownership rights and Bodega's lack of legal basis for possession.