- Petitioner
- Desiderio Dalisay Investments
- Respondent
- Social Security System
- Citation
- G.R. No. 231053
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Velasco, Jr., J.
- Decided
- April 4, 2018
Summary
This case involves a dation in payment dispute between Desiderio Dalisay Investments, Inc. (DDII) and the Social Security System (SSS). DDII owed SSS unpaid premium contributions of P4,421,321.62 and offered real property initially valued at P3.5 million, later reduced to P2 million, to partially settle the obligation. SSS accepted the offer through formal resolution and DDII delivered possession of the property in 1982. Twenty years later, DDII filed an action to quiet title, claiming no valid dation occurred and demanding back rentals. The Supreme Court ruled that there was a perfected and consummated dation in payment contract, finding that SSS's acceptance was absolute and unqualified, and that delivery of possession constituted valid tradition transferring ownership under Civil Code provisions. The decision clarifies the requirements for valid dation in payment contracts and the legal effects of delivery in transferring property ownership, while also demonstrating the application of laches doctrine in property disputes.