GR 97882; (August, 1996) (Digest)
G.R. No. 97882 August 28, 1996
THE CITY OF ANGELES, HON. ANTONIO ABAD SANTOS, in his capacity as MAYOR of Angeles City, and the SANGGUNIANG PANLUNGSOD OF THE CITY OF ANGELES, petitioners, vs. COURT OF APPEALS and TIMOG SILANGAN DEVELOPMENT CORPORATION, respondents.
FACTS
Timog Silangan Development Corporation, owner/developer of the Timog Park residential subdivision, donated 51 parcels of land to the City of Angeles via an Amended Deed of Donation. The deed stipulated that the properties, constituting the subdivision’s required open space, shall be used solely as the site for an Angeles City Sports Center, excluding cockfighting. It expressly prohibited the construction of commercial buildings, markets, or similar complexes. The deed further granted the donor the right to approve plans and any modifications, and provided that a substantial breach would entitle the donor to rescind the donation.
In 1988, the City of Angeles commenced construction of a drug rehabilitation center on a portion of the donated land. Timog Silangan protested this as a violation of the deed’s conditions, offering an alternative site which the City rejected. The developer filed a complaint for revocation of the donation. The City defended its action, arguing the conditions were contrary to a local ordinance and that the center’s purpose was later changed to a “sports development and youth center.”
ISSUE
The primary issue is whether the City of Angeles, as donee, violated the conditions of the donation by constructing a drug rehabilitation center, thereby justifying its rescission by the donor.
RULING
The Supreme Court ruled in favor of the donor, Timog Silangan, and upheld the rescission of the donation. The Court affirmed that a donation, especially one with an onerous cause like complying with open-space requirements, can be subject to valid conditions imposed by the donor. The Amended Deed of Donation clearly and expressly limited the use of the property to a Sports Center and prohibited other constructions. The construction of a drug rehabilitation center constituted a substantial breach of these conditions.
The Court rejected the City’s defense that the conditions were void for being contrary to the Subdivision Ordinance. The ordinance required dedicating open space for public use but did not prohibit the donor from imposing specific conditions on its use upon donation to the local government. The donor’s right to dictate the use is a contractual prerogative that does not contravene the law. Furthermore, the City’s subsequent attempt to re-label the facility did not cure the breach, as the physical structure and intended operation as a rehabilitation center remained incompatible with the stipulated use as a Sports Complex. Consequently, the donor validly exercised its contractual right to rescind the donation under the deed’s terms.