Title
Boyer-Roxas vs. Court of Appeals
Case
G.R. No. 100866
Decision Date
Jul 14, 1992
Petitioners, heirs of Eugenia V. Roxas, claimed co-ownership of corporate property but were ordered to vacate. Court upheld corporate separateness, denied due process claim, and applied Article 448 for unfinished building.

Case Digest (G.R. No. 100866)
Expanded Legal Reasoning Model

Facts:

  • Parties and Causes of Action
    • Heirs of Eugenia V. Roxas, Inc. (plaintiff) filed two ejectment suits:
      • RTC Civil Case No. 802-84-C against Rebecca Boyer-Roxas
      • RTC Civil Case No. 803-84-C against Guillermo Roxas
    • Petitioners claimed co-ownership of Hidden Valley Springs Resort as heirs of Eugenia V. Roxas; respondent corporation alleged petitioners occupied corporate-owned houses by mere tolerance without paying rent.
  • Background of Property Use and Improvements
    • Hidden Valley Springs Resort, located in Limao, Calauan, Laguna, developed by respondent corporation on land covered by TCT No. 32639.
    • Three buildings involved:
      • Staff house near Balugbugan Pool occupied by Rebecca B. Roxas, built with corporate funds.
      • Unfinished house erected by Rebecca and husband Eriberto Roxas, funded by the couple.
      • Recreation hall converted into Guillermo Roxas’s residence, built with corporate funds and materials from a film producer.
  • Procedural History
    • RTC rendered judgment ordering:
      • Ejectment of petitioners from respective houses
      • Payment of P300/month occupancy rent from September 10, 1983
      • Removal of unfinished building and P100/month rent for it
      • Costs
    • Court of Appeals affirmed. Petitioners filed petition for review with the Supreme Court.

Issues:

  • Whether petitioners were denied due process by the gross negligence of their counsel.
  • Whether the corporate veil should be pierced to recognize petitioners’ co-ownership rights over the resort properties.
  • Whether the trial court erred in ordering petitioner Rebecca Boyer-Roxas to remove the unfinished building, notwithstanding her expenditure of personal funds.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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