G.R. No. 220042 - Casa Milan Homeowners Association, Inc. vs. The Roman Catholic Archbishop of Manila

The case is a petition for review under Rule 45 of the Rules of Court seeking to reverse:

The Court of Appeals’ Decision dated 20 January 2015;
The Resolution dated 10 August 2015, which affirmed the earlier trial court ruling.

The Regional Trial Court (RTC) of Quezon City, Branch 100, had dismissed the petitioner's complaint for failure to state a cause of action, a ruling later confirmed by the Court of Appeals.

B.C. Regalado & Co., Inc. originally owned the lots of the Casa Milan Subdivision in North Fairview, Quezon City.
The approved subdivision plan of Casa Milan designated Lot 34, Block 143 (totaling 6,083 square meters) as an open space or park/playground, with ownership evidenced by Transfer Certificate of Title (TCT) No. RT-78112 in Regalado’s name.

In 1995, the Roman Catholic Archbishop of Manila (RCAM) started constructing a church on a portion of Lot 34, Block 143.
In June 1995, RCAM (through the developer New North Fairview Realty and Development, Inc.) applied with the Housing and Land Use Regulatory Board (HLURB) for the segregation of a 4,000-square meter portion of Lot 34 to be used as a parish church.
The HLURB, in its Executive Brief, noted that the request was supported by a letter from residents rather than by the then non-existent Casa Milan Homeowners Association, Inc. (the petitioner), which was incorporated only in 1999.

On 29 October 2002, during the pendency of the petition for conversion, Regalado executed a Deed of Donation transferring the 4,000-square meter portion of Lot 34 to RCAM.
On 5 March 2007, the City Council of Quezon City, through a Resolution signed by then Vice-Mayor Herbert Bautista, approved the segregation request and authorized the conversion of the said lot into a multipurpose center.

The 4,000-square meter area was issued TCT No. N-305323 in RCAM’s name;
The remaining 2,083 square meters, still in Regalado's name, was issued TCT No. N-305324.

On 3 December 2009, petitioner Casa Milan Homeowners Association, Inc. filed a complaint against RCAM, Regalado, the developer, and the Register of Deeds of Quezon City.
The complaint asserted two main causes of action:

The Deed of Donation was invalid because it was executed without the required written consent of the homeowners association or the majority of residents;
RCAM acted in bad faith by erecting a parish church on the disputed open space without color of title.

Issuance of a temporary restraining order and/or writ of preliminary injunction to halt RCAM’s construction activities;
Cancellation of TCT Nos. 305323 and 305324 and restoration of the original TCT No. RT-78112;
Demolition of the improvements by RCAM and turnover of peaceful possession of the open space to the petitioner;
Payment of costs.

The RTC granted the motion, dismissing the complaint for lack of a cause of action.
Petitioner’s subsequent Motion for Reconsideration was denied on 2 September 2011.

The Court of Appeals affirmed the trial court’s ruling on 20 January 2015 by holding that:

Nowhere did the complaint establish that the petitioner had acquired any legal right over the open space that would require RCAM to secure its written consent;
The petitioner’s causes of action were insufficient.

The petitioner’s further Motion for Reconsideration before the Court of Appeals was also denied, prompting the present petition for review.

The case involves interpretation of the provisions of Presidential Decree No. 957 as amended by PD No. 1216, particularly Section 31, which governs the allocation and disposition of open spaces in residential subdivisions.
Jurisprudence, including the 1991 and 1998 White Plains cases and the Republic v. Spouses Llamas decision, elucidates the freedom of subdivision developers and owners in the disposition of open spaces, emphasizing that donation to local government or homeowners associations requires a positive act.

Whether the Court of Appeals committed grave reversible error in affirming the dismissal of the complaint for failure to state a cause of action.
Whether the Court of Appeals committed grave reversible error in ruling that the action is barred by prior judgment (res judicata).
Whether the Court of Appeals committed grave reversible error in ruling that the action is barred by litis pendentia.