Case Digest (G.R. No. 202342)
Facts:
The case "AMA Land, Inc. vs. Wack Wack Residents' Association, Inc." involved a dispute between AMA Land, Inc. (hereafter referred to as AMALI), the petitioner, and the Wack Wack Residents' Association, Inc. (WWRAI), the respondent. The conflict centers on a commercial and residential building project proposed by AMALI in the mid-1990s at the junction of Epifanio Delos Santos Avenue and Fordham Street in Mandaluyong City. As part of its plan, AMALI sought to use Fordham Street as an access road for its construction. On March 18, 1996, AMALI notified WWRAI of its intention to utilize this road, but WWRAI did not respond. Despite this, AMALI proceeded to set up a job site and field office on Fordham Street.
WWRAI subsequently filed a petition claiming AMALI had illegally transformed part of the street for construction purposes. On May 8, 1996, AMALI filed a petition with the Regional Trial Court (RTC) of Pasig City, seeking temporary and permanent easements of r
Case Digest (G.R. No. 202342)
Facts:
- AMA Land, Inc. (AMALI) proposed a commercial and residential project, the AMA Tower, in Wack Wack Village, Mandaluyong City, in the mid‑1990s.
- AMALI secured numerous permits and licenses—including a Building Location Permit, Certificate of Locational Viability, Locational Clearance, Excavation and Ground Preparation Permit, Building Permit, Environmental Compliance Certificate, HLURB Certificate of Registration, and HLURB License to Sell—to proceed with its project.
- On March 18, 1996, AMALI notified the Wack Wack Residents’ Association, Inc. (WWRAI), a registered homeowners’ association owning Fordham Street, of its intention to use that street as an access road and staging area for the project.
- WWRAI claimed that AMALI had already converted a part of Fordham Street—even prior to the said notification—into a barrack site and staging area, and all efforts by WWRAI to remove the field office set up by AMALI were unsuccessful.
Background of the Dispute
- AMALI filed a petition before the Regional Trial Court (RTC) seeking relief based on Article 656 of the Civil Code for:
- A temporary easement of right of way over a portion of Fordham Street;
- A permanent easement of right of way;
- A temporary restraining order (TRO) to enjoin WWRAI from demolishing AMALI’s temporary field office and constructing fencing; and
- A writ of preliminary mandatory injunction to ensure AMALI’s uninterrupted access to the intended construction site.
- In response, WWRAI argued that AMALI’s project violated applicable zoning ordinances, that its permits were irregular and unlawful, that the project constituted a nuisance, and that the main thoroughfare EDSA might serve as an alternative access route.
- On July 24, 1997, the RTC granted a writ of preliminary mandatory injunction directing WWRAI to allow AMALI temporary use of Fordham Street through a temporary easement of right of way.
- The matter evolved as AMALI’s construction halted in 1998 due to a financial crisis but resumed later, resulting in subsequent RTC rulings:
- On October 28, 2010, the RTC denied WWRAI’s urgent application for a TRO and/or writ of preliminary injunction, effectively ordering AMALI to engage with Mandaluyong City’s Building Officials regarding its permits.
- A motion for reconsideration was denied on February 23, 2011.
Initial Litigation and RTC Proceedings
- WWRAI filed a petition before the Court of Appeals (CA), which reversed and set aside the RTC Orders of October 28, 2010 and February 23, 2011, and ordered the RTC to issue injunctive relief pending the resolution of the permanent easement petition.
- Additionally, the CA directed WWRAI to amend its petition—including disclosing the names of its principals and clarifying that the action was in a representative capacity.
- AMALI then filed a petition for review on certiorari under Rule 45 of the Rules of Court challenging the CA Decision, prompting the Supreme Court’s review.
Appellate and Certiorari Proceedings
Issue:
- AMALI questioned the propriety of WWRAI’s strategy in pursuing parallel remedies.
Whether WWRAI engaged in forum shopping by filing multiple petitions in different forums.
- This issue centers on whether the alleged construction activities constitute an immediate threat of irreparable injury.
Whether WWRAI is entitled to a temporary restraining order (TRO) and/or a writ of preliminary injunction.
- AMALI argued that the CA’s ruling interfered with the determination of disputed facts in the main case.
Whether the CA Decision constitutes a prejudgment of the merits of the original petition (Civil Case No. 65668) for permanent easement of right of way.
- The analysis involved clarifying which situation—the pre-action condition or subsequent developments—should be preserved.
Whether the CA Decision disturbed the status quo existing before WWRAI’s petition was filed.
- The contention focused on whether the association or its individual members should be considered the proper litigants.
Whether WWRAI is the real party in interest in the dispute regarding the easement of right of way over Fordham Street.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)