Title
Agdao Landless Residents Association, Inc. vs. Maramion
Case
G.R. No. 188642
Decision Date
Oct 17, 2016
ALRAI members expelled without due process; land transfers violated donation terms; SC upheld CA, restoring membership, annulling void transfers, and requiring accounting records.
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Case Digest (G.R. No. 188642)

Facts:

Parties Involved:

  • Petitioners: Agdao Landless Residents Association, Inc. (ALRAI), a non-stock, non-profit corporation, and its board of directors, including Armando Javonillo, Ma. Acelita Armentano, Alex Josol, Salcedo de la Cruz, Jr., Claudio Lao, Antonia Amorada, Julius Alinsub, Pompeniano Espinosa, Consorcio Delgado, Romeo Cabillo, Benjamin Lamigo, Ricardo Bacong, Rodolfo Galenzoga, and Asuncion Alcantara.
  • Respondents: Rolando Maramion, Leonidas Jamisola, Virginia Canoy, Elizabeth Gonzales, Crispiniano Quire-Quire, Emestino Dunlao, Ella Demandante, Ella Ria Demandante, Elgin Demandante, Satumina Witara, Virgilio Dayondon, Melencia Maramion, Angelica Penkian, Presentacion Tan, Hemani Gregory, Rudy Gimarino, Valentin Cameros, Radel Cameros, Zoilo Jabonete, Luisito Tan, Joseph Quire-Quire, Emestino Dunlao, Jr., Fred Dunlao, Liza Maramion, Clarita Robilla, Renata Dunlao, and Prudencio Juariza, Jr.

Background:

  • Dakudao & Sons, Inc. (Dakudao) donated 46 titled lots to ALRAI through six Deeds of Donation. One deed prohibited ALRAI from partitioning or distributing individual certificates of title within five years unless written authority was secured from Dakudao. Violation would render the donation void, reverting title and possession to Dakudao.
  • In 2000, ALRAI’s board and stockholders resolved to transfer 10 donated lots to individual members and non-members, including petitioners Javonillo, Armentano, and Alcantara, as well as Romeo Dela Cruz and Lily Loy.
  • Respondents, allegedly ousted members of ALRAI, filed a complaint against petitioners, accusing them of:
    1. Expelling members without due process.
    2. Selling donated lands in violation of the Deeds of Donation.
    3. Failing to produce ALRAI’s accounting books.
    4. Charging exorbitant fees contrary to ALRAI’s By-Laws.

RTC Decision:

  • The Regional Trial Court (RTC) ruled in favor of respondents, annulling the transfers of the donated lots, restoring respondents’ membership, and ordering petitioners to produce ALRAI’s accounting books.

CA Decision:

  • The Court of Appeals (CA) affirmed the RTC’s decision with modifications, declaring some transfers valid (e.g., to Dela Cruz and Loy) and others void (e.g., to Javonillo and Armentano). The CA upheld the annulment of transfers violating the five-year restriction in the Deeds of Donation.

Issue:

  1. Whether respondents were validly expelled from ALRAI without due process.
  2. Whether the transfers of donated lots violated the Deeds of Donation and ALRAI’s Constitution and By-Laws.
  3. Whether Lily Loy was a buyer in good faith.
  4. Whether petitioners were required to produce ALRAI’s accounting books and receipts.

Ruling:

  • The Supreme Court upheld the CA’s decision, ruling that:
    1. Respondents were expelled without due process and were entitled to restoration of their membership.
    2. Transfers to Javonillo and Armentano violated ALRAI’s Constitution, while transfers to Dela Cruz and Alcantara were valid.
    3. Lily Loy was not a buyer in good faith.
    4. Petitioners were required to produce ALRAI’s accounting books and receipts for inspection by members.

Ratio:

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