The Roman Catholic Archbishop of Manila v. Hon. Court of Appeals

Summary

Estate representatives of deceased donors sued Catholic Church entities and buyer spouses to nullify a 1930 deed of donation and subsequent 1980 sale, claiming violation of a 100-year non-alienation condition. The trial court dismissed for prescription, but the Court of Appeals reversed, finding the automatic reversion clause made the standard four-year prescriptive period inapplicable. However, the Supreme Court ultimately dismissed the case on different grounds, ruling that the 100-year prohibition against alienation was an unreasonable restriction on ownership rights and therefore invalid under Civil Code Article 727. With the prohibitory condition void, the subsequent sale was valid, leaving the estate without cause of action. The decision clarifies that while parties may include automatic reversion clauses in donations, such conditions must not unreasonably restrict fundamental ownership rights.