Case Digest (G.R. No. 166744) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In AC Enterprises, Inc. (ACEI) v. Frabelle Properties Corporation (FPC), decided November 2, 2006 under the 1987 Constitution, ACEI owns the ten‐storey Feliza Building in Legaspi Village, Makati City, served by 36 air‐conditioning blowers on its upper floors. FPC, developer of the adjacent 29‐storey Frabella I Condominium directly facing Feliza Building across a 12‐meter street, repeatedly demanded from April 1995 that ACEI abate the “unbearable noise” and hot‐air blast from those blowers. Testing by the EMB of the DENR in 1995, 1996 and 2000 confirmed noise levels beyond the legal limits under Section 78(b) of P.D. 984. ACEI refused relief. In March 2001 the Frabella I Condominium Corporation filed a PAB complaint for pollution abatement, which the PAB dismissed as a private nuisance case and endorsed to the local government. FPC then sought intervention from the Makati City Health Officer, Mayor and City Building Official, but was told the EMB should decide and that other fact Case Digest (G.R. No. 166744) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Properties
- Petitioner AC Enterprises, Inc. (ACEI) owns the 10-story Feliza Building in Makati City, subdivided into commercial/office units. It has 36 blowers from 18 air-cooled airconditioning units (4 per floor, 2nd–10th floors), covered by vertical concrete baffles.
- Respondent Frabelle Properties Corporation (FPC) developed Frabella I Condominium, a 29-story commercial/residential building on a parallel street. Feliza Building is at its rear, separated by Rodriguez Street (12 m wide), and its blowers exhaust toward Frabella I.
- Correspondence and Environmental Tests
- April–June 1995: FPC’s demand letters to ACEI to abate daily noise and hot-air nuisance; ACEI refused.
- August 1995–July 1996: DENR-EMB tests found blower noise exceeded PD 984 Sec. 78(b) standards.
- August & November 2000: Further EMB tests with same results; ACEI ignored demands.
- Administrative and Quasi-Judicial Proceedings
- March–July 2002: FPC sought Makati City Health Officer and Mayor’s intervention. EMB panel (May 2002) reported ambient noise contributed by vehicles and nearby blowers, endorsed matter back to City; City Building Official (July 2002) advised refer back to EMB.
- February–November 2003: EMB conducted SPL measurements inside Frabella I; opined that nuisance depends on disturbance, not ambient standards alone.
- Judicial Proceedings in RTC
- July 2003: FPC filed in Malabon RTC (Civil Case No. 3742-MH) a complaint for private nuisance abatement, preliminary and permanent injunction, and damages (temperate, exemplary, attorney’s fees).
- ACEI moved to dismiss for: (a) lack of jurisdiction (LGU vs. court), (b) failure to state cause of action, (c) res judicata, litis pendentia, forum-shopping.
- September 15, 2003: RTC denied motion to dismiss, finding urgency and sufficiency of complaint; motion for reconsideration denied.
- September 21, 2004: CA affirmed RTC; CA denied ACEI’s motion for reconsideration.
- ACEI filed petition for certiorari before the Supreme Court.
Issues:
- Does the Makati City Government, not the RTC, have exclusive jurisdiction over the abatement of the complained noise and air nuisance?
- Is the suit barred for failure to exhaust administrative remedies and for non-application of the doctrine of primary jurisdiction?
- Are the proceedings barred by res judicata, litis pendentia, or forum-shopping (PAB case and City Official’s letter)?
- Does FPC’s complaint state a valid cause of action for abatement of nuisance and damages?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)