Case: C-J YULO & SONS, INC. vs. ROMAN CATHOLIC BISHOP OF SAN PABLO, INC (G.R. No.

133705. March 31, 2005)

Facts: C-J Yulo & Sons donated a parcel of land containing an area of 41,117 square meters
to Roman Catholic Bishop of San Pablo with a condition to establish, operate and
maintain such a home for the aged. Yulo & Sons revoked the donation for breach of
the condition, RTC ruled in their favor, while CA reversed the decision.

Issue: Whether or not the revocation is valid

Ruling: Revocation is invalid.

To warrant the revocation of the donation, casual breach of the deed is not
sufficient there must be substantive breach.

Donations, according to its purpose or cause, may be categorized as: (1) pure or
simple; (2) remuneratory or compensatory; (3) conditional or modal; and (4)
onerous.

An onerous donation is that which imposes upon the donee a reciprocal obligation
or, to be more precise, this is the kind of donation made for a valuable consideration,
the cost of which is equal to or more than the thing donated.

The validity of and the rights and obligations of the parties involved in an
onerous donation is completely governed not by the law on donations but by
the law on contracts. In this regard, Article 733 of the New Civil Code provides:
ARTICLE 733 Donations with onerous cause shall be governed by the
rules on contracts, and remuneratory donations by the provisions of the
present Title as regards that portion which exceeds the value of the
burden imposed.
The prescription period is 10 years.
The Court of Appeals correctly applied the law on contracts instead of the law
on donations because the donation involved in this case is onerous, saddled as it
is by a burden imposed upon the donee to put up and operate a home for the
aged and the infirm.
SC cited the case of Republic vs. Silim

SC discussed prescription as it was also an issue in this case. Casual breach of the
condition causes the revocation invalid.