GR 126444; (December, 1998) (Digest)
G.R. No. 126444. December 4, 1998.
ALFONSO QUIJADA, et al., petitioners, vs. COURT OF APPEALS, REGALADO MONDEJAR, et al., respondents.
FACTS
Petitioners, heirs of Trinidad Quijada, filed a complaint to quiet title and recover possession of a two-hectare parcel of land. The land was originally inherited by Trinidad from her father. In 1956, Trinidad and her siblings executed a conditional deed of donation over the property in favor of the Municipality of Talacogon, with the condition that it be used solely as part of the campus of a proposed provincial high school. Despite the donation, Trinidad remained in possession. In 1962 and subsequently, she sold the entire property to respondent Regalado Mondejar. The proposed high school never materialized, and in 1987, the municipal council enacted a resolution reverting the land to the donors. Mondejar, in the interim, had sold portions of the land to other respondents.
ISSUE
The core issue is whether the sale of the property by Trinidad Quijada to Regalado Mondejar in 1962 and later years was valid, considering the prior donation to the municipality.
RULING
The Supreme Court affirmed the Court of Appeals’ ruling that the sale was valid. The legal logic rests on the nature of the conditional donation. While the donation was perfected and ownership transferred to the municipality upon its acceptance, the deed contained an automatic reversion clause stating the property would revert to the donors if the high school was not established. This clause created a resolutory condition. Consequently, upon the non-fulfillment of the condition (the failure to establish the school), ownership would automatically revert to the donors without need of a further act. Crucially, the Court held that this stipulation vested in the donor, Trinidad Quijada, an inchoate interest or expectant right in the property during the subsistence of the donation. This residual interest was a patrimonial property right that she could validly alienate or assign. Therefore, her sales to Mondejar were not void but constituted a valid transfer of her contingent right to the property. The subsequent municipal resolution in 1987 merely confirmed the reversion that was already stipulated to occur automatically by the terms of the deed itself. The Court thus upheld the validity of the sales from Trinidad to Mondejar and from Mondejar to the other respondents.