Case Digest (G.R. No. 160273) Core Legal Reasoning Model
Facts:
In Cebu Country Club, Inc. (CCCI) vs. Ricardo F. Elizagaque (G.R. No. 160273, January 18, 2008), the petitioners are CCCI, a non-stock, non-profit private membership club in Cebu City, and its directors Sabino R. Dapat, Ruben D. Almendras, Julius Z. Neri, Douglas L. Luym, Cesar T. Libi, Ramontito E. Garcia and Jose B. Sala. In 1987 San Miguel Corporation designated respondent Elizagaque as a special non-proprietary member of CCCI, which the Board approved. In 1996 he applied for proprietary membership, was indorsed by two existing proprietary members, and acquired a share certificate after buying a share for ₱3 million. Although CCCI issued Certificate No. 1446 on September 6, 1996, the Board deferred action in meetings on April 4 and May 30, 1997, and on July 30, 1997 secret-ballot voting produced one black ball, thus failing the unanimous vote required by the amended By-Laws. On August 1, 1997 he was informed of disapproval. His letters for reconsideration and inquiry went un
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Case Digest (G.R. No. 160273) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Cebu Country Club, Inc. (CCCI) is a non-stock, non-profit private membership club in Cebu City. Petitioners are members of its Board of Directors.
- Ricardo F. Elizagaque was designated in 1987 as a special non-proprietary member by San Miguel Corporation. In 1996, he applied for proprietary membership, secured endorsements, purchased a proprietary share, and received Certificate No. 1446.
- Procedural History
- The CCCI Board deferred action on Elizagaque’s application in April and May 1997. At the July 30, 1997 meeting, one black ball blocked unanimous approval; on August 1, 1997, the Secretary notified him of disapproval. Elizagaque’s letters of reconsideration in August, October, and November 1997 went unanswered.
- On December 23, 1998, Elizagaque sued in RTC Pasig (Civil Case No. 67190) for damages. On February 14, 2001, the RTC awarded P2.34 M actual, P5 M moral, P1 M exemplary damages, P1 M attorney’s fees, and P80 000 litigation expenses.
- The Court of Appeals, in its January 31, 2003 Decision, affirmed with modification: P2 M moral, P1 M exemplary damages, P500 000 attorney’s fees, P50 000 litigation expenses. Motions for reconsideration were denied on October 2, 2003. Petitioners filed this Rule 45 petition.
Issues:
- Whether petitioners, in disapproving Elizagaque’s application for proprietary membership, acted in bad faith or fraud, thus incurring liability for damages.
- Whether petitioners can be held jointly and severally liable.
- Whether the amounts awarded for moral, exemplary damages, attorney’s fees, and litigation expenses are excessive or proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)