Thursday, December 10, 2020

Republic vs Silim [G.R. No. 140487] Case Digest

 

Republic vs Silim

G.R. No. 140487

 

Facts:

Spouses Leon Silim and Ildefonsa Mangubat, donated a 5,600 square meter parcel of land in favor of the Bureau of Public Schools, Municipality of Malangas, Zamboanga del Sur. In the Deed of Donation, respondents imposed the condition that the said property should "be used exclusively and forever for school purposes only." This donation was accepted by Gregorio Buendia, the District Supervisor of BPS.

The Bagong Lipunan school building that was supposed to be allocated for the donated parcel of land in Brgy. Kauswagan could not be released since the government required that it be built upon a one (1) hectare parcel of land. To remedy this predicament, ASDS of the said Province authorized District Supervisor Buendia to officially transact for the exchange of the 1/2 hectare old school site of Kauswagan Elementary School to a new and suitable location which would fit the specifications of the government. Buendia and Teresita Palma entered into a Deed of Exchange whereby the donated lot was exchanged with the bigger lot owned by the latter. The Bagong Lipunan school buildings were constructed on the new school site and the school building previously erected on the donated lot was dismantled and transferred to the new location.

Respondents filed a Complaint for Revocation and Cancellation of Conditional Donation among others before RTC Pagadian. RTC dismissed the case for lack of merit. CA reversed the decision of the trial court and declared the donation null and void.

 

Issue:

Whether or not the Donation is null and void due to an alleged violation of a condition in the donation.

 

Held:

No.

 

Ratio:

The condition for the donation was not in any way violated when the lot donated was exchanged with another one. The purpose for the donation remains the same, which is for the establishment of a school. The exclusivity of the purpose was not altered or affected. In fact, the exchange of the lot for a much bigger one was in furtherance and enhancement of the purpose of the donation. The acquisition of the bigger lot paved the way for the release of funds for the construction of Bagong Lipunan school building which could not be accommodated by the limited area of the donated lot.

 

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