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. 219491)

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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