Case Digest (G.R. No. 211780) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cezar Yatco Real Estate Services, Inc. et al. v. Bel-Air Village Association, Inc. (G.R. No. 211780, October 21, 2019), the Makati Development Corporation developed Bel-Air Village in the 1950s and sold residential lots subject to Deed Restrictions lasting fifty years from January 15, 1957 to January 15, 2007. These restrictions—including automatic membership in the Bel-Air Village Association, Inc. (“Association”)—were annotated on the purchasers’ land titles under Act 496, § 39. In 1998, the Association formed a 2007 Committee to propose amendments in anticipation of expiration. After circulating drafts and obtaining homeowners’ feedback, a special board resolution was passed in October 2006, followed by a special general membership meeting on December 12, 2006 at which 718 of 934 eligible members attended. Seventy-two percent of votes cast approved extending the term of the Deed Restrictions to August 23, 2032. Petitioners Cezar Yatco Real Estate Services, GRD Property Res Case Digest (G.R. No. 211780) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Development and Deed Restrictions
- In the 1950s, Makati Development Corporation (MDC) developed Bel-Air Village, selling lots under Deed Restrictions effective January 15, 1957 to January 15, 2007.
- The Deed Restrictions comprised seven parts, including:
- Automatic membership in Bel-Air Village Association, Inc. (BAVA) with lien powers;
- Uses of lots (residential only, setbacks, easements);
- Architectural controls;
- Sewage and wall regulations;
- A “Term of Restrictions” clause giving a 50-year duration and a proviso that the Association “may … add new ones, amend or abolish particular restrictions or parts thereof by majority rule”; and
- Enforcement by MDC, BAVA or any lot owner.
- Association Formation and Term-Extension Process
- BAVA was organized as a non-stock, non-profit homeowners’ association; by-laws made all lot owners automatic members and empowered the Association to amend restrictions by majority vote.
- In 1998, BAVA’s “2007 Committee” solicited homeowner input. In June–October 2006, proposed amendments—including extending the term to August 23, 2032—were drafted, circulated, and approved by BAVA’s Board.
- On December 12, 2006, a special membership meeting was held: 718 of 934 members in good standing attended, with 72% voting for the extension, 3% against, and 25% abstaining.
- Legal Challenges and Procedural History
- February 8, 2007: Petitioners (all of whom voted against the extension) filed a Verified Complaint with the Housing and Land Use Regulatory Board (HLURB), alleging that the 50-year term was not amendable, that no quorum existed due to non-notarized proxies, and that compulsory membership violated freedom of association.
- May 21, 2008: HLURB Arbiter declared the extension and new restrictions null and void, ruling the term non-amendable and proxies invalid for lack of notarization.
- December 9, 2008: HLURB Board of Commissioners reversed the Arbiter, upholding the extension by majority vote and validating the proxies.
- January 28, 2009: Denial of petitioners’ motion for reconsideration by the HLURB Board.
- December 29, 2009: Office of the President (OOP) reversed the HLURB Board, reinstating the Arbiter’s decision—holding the term non-extendible, proxies require notarization under the Civil Code, and membership mandatory.
- May 19, 2011: OOP granted reconsideration, reversed its own decision, and upheld the extension—recognizing the 50-year term as part of the amendable covenants, noting Ayala Land, Inc.’s confirmation as MDC’s successor, applying the Corporation Code for proxies, and rejecting freedom-of-association claims against a private association.
- September 5, 2013 (CA) and March 17, 2014 (CA Resolution): Court of Appeals affirmed the OOP May 19, 2011 Resolution.
- Petitioners filed a Verified Petition for Review on Certiorari under Rule 45 of the Rules of Court before the Supreme Court.
Issues:
- Whether BAVA members may, by majority vote, extend the Deed Restrictions’ 50-year term.
- Whether the extension was validly adopted given the alleged lack of quorum and non-notarized proxies.
- Whether petitioners can be compelled to maintain membership in BAVA against their will.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)