Case Digest (G.R. No. 124371)
Facts:
In Alabang Corporation, Development Petitioner vs. Alabang Hills Village Association and Rafael Tinio (G.R. No. 187456, June 2, 2014), the Alabang Development Corporation (ADC) filed on October 19, 2006 a Complaint for Injunction and Damages against Alabang Hills Village Association, Inc. (AHVAI) and its president, Rafael Tinio, before the Regional Trial Court (RTC) of Muntinlupa City, Branch 276. ADC alleged that, as the original developer of Alabang Hills Village, it retained ownership of certain parcels—including open spaces—and that AHVAI had commenced construction of a multipurpose hall and swimming pool on an unsold lot without ADC’s consent. Despite ADC’s demand to desist, construction proceeded. ADC prayed for injunctive relief. AHVAI answered, contending (1) that ADC’s corporate existence was already revoked by the Securities and Exchange Commission (SEC) on May 26, 2003 and thus ADC lacked capacity to sue; (2) that ADC held the property in trust for AHVAI as beneficialCase Digest (G.R. No. 124371)
Facts:
- Parties and background
- Petitioner Alabang Development Corporation (ADC) is the original developer of Alabang Hills Village, owning unsold parcels and designated open spaces.
- Respondents Alabang Hills Village Association, Inc. (AHVAI) and its president, Rafael Tinio, represent the homeowners' association.
- Complaint for Injunction and Damages (RTC Muntinlupa City, Oct. 19, 2006)
- ADC alleged that in September 2006 AHVAI commenced construction of a multi-purpose hall and swimming pool on ADC’s unsold parcel without consent.
- ADC demanded cessation; upon refusal, it filed for injunctive relief and damages.
- Respondents’ Answer and Counterclaim
- AHVAI denied ADC’s capacity to sue—its corporate charter was revoked by the SEC on May 26, 2003—and claimed beneficial ownership and that the lot was legally reserved open space.
- AHVAI’s counterclaim sought to divest ADC of title, declare AHVAI the owner, and award moral/exemplary damages and attorney’s fees; Tinio adopted similar defenses.
- RTC Decision (Jan. 4, 2007)
- Dismissed ADC’s complaint on grounds of:
- Lack of juridical personality;
- Subject lot as reserved open space;
- Exclusive HLURB jurisdiction over subdivision disputes.
- RTC approved ADC’s appeal but dismissed AHVAI’s counterclaim as dependent on the invalidated complaint.
- Court of Appeals Decision (Mar. 27, 2009, CA-G.R. CV No. 88864)
- Dismissed ADC’s appeal, affirming RTC’s finding that ADC lacked capacity to sue.
- Dismissed AHVAI’s appeal on counterclaim—without a valid main claim, counterclaims are improper.
- Supreme Court Petition (G.R. No. 187456, June 2, 2014)
- ADC challenged the CA’s reliance on Columbia Pictures, Inc. v. CA for capacity doctrine.
- ADC argued the CA erred in finding lack of capacity under Section 122, Corporation Code.
- ADC contended the CA failed to address its alleged statutory obligation to cede properties to AHVAI.
Issues:
- Whether the Court of Appeals erred in relying on Columbia Pictures, Inc. v. Court of Appeals to determine ADC’s capacity to sue.
- Whether ADC retained capacity to file suit beyond the three-year liquidation period under Section 122, Corporation Code.
- Whether the CA failed to resolve ADC’s alleged mandate to cede properties to AHVAI.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)