G.R. No. 171832 - Antipolo Properties, Inc. vs. Nuyda

On February 14, 1991, petitioner Antipolo Properties, Inc. (now Prime East Properties, Inc.), a realty development company, entered into a Kasunduan with Magtanim Upang Mabuhay, Inc. (MUMI), an association comprising alleged illegal settlers in the Melitona estate and the Ozaeta lots in Binangonan, Rizal.
Under the February 14, 1991 Kasunduan, MUMI members agreed to vacate the estate and relocate to a resettlement area so that petitioner could develop the property into a residential and commercial complex.
Petitioner’s obligations under the agreement included developing the resettlement area, subdividing and awarding lots therein to the association’s members, and disbursing disturbance compensation to those displaced.

On June 7, 1991, petitioner and respondent Cesar Nuyda, a member of MUMI, entered into another agreement also called a Kasunduan.
In this June 7, 1991 Kasunduan, petitioner recognized respondent’s membership in MUMI and committed to awarding him a lot of not less than 2,880 square meters in the resettlement area, in addition to guaranteeing him disturbance compensation.
Respondent, for his part, was to vacate the portion of the estate he occupied and relocate to the resettlement area, in consonance with the agreement.

In 1998, after petitioner demolished improvements on the estate (including those made by respondent), petitioner reneged on its obligations prescribed in the June 7, 1991 Kasunduan.
Consequently, respondent initiated a legal action for specific performance and damages before the Regional Trial Court (RTC) of Pasig City (Civil Case No. 66967).
In his answer, petitioner disputed respondent’s membership in MUMI and argued that even if respondent were a member, he did not qualify as envisaged in the February 14, 1991 Kasunduan.

After a trial on the merits, the RTC rendered a decision on May 20, 2001, declaring both the February 14 and June 7, 1991 Kasunduan as valid and binding between the parties, thereby ordering petitioner to perform its contractual obligations.
The RTC’s ruling included specific orders:

Dissatisfied with the RTC decision, petitioner appealed to the Court of Appeals (CA).
In its August 31, 2005 decision, the CA affirmed the RTC ruling, rejecting petitioner’s arguments regarding respondent’s membership status and the alleged irregular signing process (rubber-stamp signature versus original signature).
The CA ruled that, based on the clear and unambiguous terms of the contract, petitioner was bound to enforce its stipulated obligations.
Further, in the March 6, 2006 resolution, the CA denied petitioner’s motion for reconsideration, prompting petitioner to file a petition for review on certiorari before the Supreme Court.

Petitioner contended that eligibility for the benefits contained in the Kasunduan should be confined to members of MUMI who were occupants in the capacity of an owner, arguing that respondent was only a caretaker.
Based on this interpretation of the February 14, 1991 Kasunduan, petitioner argued that respondent was disqualified from claiming a lot in the resettlement area and the designated disturbance compensation.
The petition asserted that such a restrictive interpretation was necessary to distinguish between actual settlers and mere caretakers, thereby limiting the scope of the contractual benefits.

Whether the Kasunduan entered into on February 14, 1991 and subsequently on June 7, 1991 constitute valid and binding agreements between the parties.
Whether the manner in which the agreements were executed (including the issue of rubber-stamped signatures versus original signature) affects their enforceability.

Whether respondent, as a member of MUMI under the Kasunduan, is entitled to the benefits specifically allocated in the agreement, including a 2,880 sq. m. lot and disturbance compensation.
Whether the interpretation of “kasapi” (member) in the agreements should be limited to property owners or should also include those in a caretaker capacity.

Whether petitioner’s prior representations and actions, including granting similar benefits to another caretaker, estop petitioner from later contesting respondent’s qualification.
Whether the clear and plain language of the contract leaves room for alternative interpretations regarding the eligibility of respondents for the contractual benefits.