Evelyn de Luna v. Hon. Sofronio F. Abrigo

Summary

The Supreme Court reversed a trial court's dismissal of an action seeking reversion of donated land for non-compliance with conditions. The original donor had donated land to Luzonian University Foundation with conditions requiring construction within five years and included an automatic reversion clause. When the donor's heirs sued for reversion after his death, the trial court dismissed the case as time-barred under the four-year prescription period for donation revocation. The Supreme Court held that onerous donations are governed by contract law, not donation law, under Article 733 of the Civil Code. The automatic reversion clause was a valid contractual stipulation, and the action to enforce the written contract was subject to the ten-year prescription period, not four years. The case was significant for clarifying that onerous donations follow contract rules and established the validity of automatic reversion clauses in donation agreements. The Court ordered reinstatement for trial on the merits.