Case Digest (G.R. No. 182779) Core Legal Reasoning Model
Facts:
This case involves Chateau de Baie Condominium Corporation (petitioner) and respondents Spouses Raymond and Ma. Rosario Moreno concerning unpaid condominium association dues and the foreclosure sale of Moreno’s condominium unit and parking slots located in Chateau de Baie Condominium, Roxas Boulevard, Manila. Mrs. Moreno is the registered owner of a penthouse unit and two parking slots covered by Condominium Certificates of Title Nos. 4153, 4154, and 4155. She became a loan debtor to Oscar Salvacion, who obtained a mortgage over these properties. Under Section 20 of Republic Act No. 4726 (the Condominium Act), condominium corporations have the right to enforce a lien for unpaid association dues via extrajudicial foreclosure.
On November 23, 2001, Chateau de Baie Condominium Corporation annotated a Notice of Assessment related to unpaid association dues of P323,870.85 on the Moreno properties covering both the penthouse unit and the parking slots. Despite a settlement offer by t
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Case Digest (G.R. No. 182779) Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners: Chateau de Baie Condominium Corporation (the condominium corporation).
- Respondents: Spouses Raymond and Ma. Rosario Moreno (registered owners of a penthouse unit and two parking slots in Chateau de Baie Condominium).
- Properties involved: Moreno properties consisting of a penthouse and two parking slots covered by Condominium Certificates of Title (CCT) Nos. 4153, 4154, and 4155.
- Mortgage and Association Dues
- Mrs. Moreno obtained a P16,600,000.00 loan from Oscar Salvacion, mortgaging the Moreno properties as security; annotated on the CCTs.
- As owners, the Morenos are liable to pay association dues to the petitioner. Unpaid dues amounted to P323,870.85, leading petitioner to annotate a Notice of Assessment on the Moreno properties’ CCTs on November 23, 2001.
- Petitioner's Steps to Enforce Lien and Extrajudicial Foreclosure
- Under Section 20 of R.A. No. 4726 (Condominium Act), a condominium corporation may enforce a lien on unpaid association dues via extrajudicial foreclosure sale.
- Following non-payment, petitioner attempted to auction the properties extrajudicially, scheduling the sale on February 10, 2005.
- The Salvacion Case (Civil Case No. 05-0061; CA-G.R. SP No. 90339; G.R. No. 178549)
- Salvacion, mortgagee, filed a petition to enjoin the extrajudicial sale arguing lack of owner’s special power to sell as required by Act No. 3135.
- RTC Branch 196 dismissed the petition and allowed the sale to proceed; Moreno properties sold to petitioner for P1,328,967.12.
- CA ruled that R.A. No. 4726 is a special law applicable to condominiums, not Act No. 3135 which governs real estate mortgages generally; hence, no special authority was needed from the owner.
- The CA upheld the extrajudicial sale’s validity; the ruling was final after denial of petitioner’s motion for reconsideration and Supreme Court’s denial of Salvacion’s petition for review.
- The Moreno Case (Civil Case No. 05-0183; CA-G.R. SP No. 93217)
- While Salvacion’s appeal was pending, the Morenos filed an intra-corporate dispute complaint with the RTC Branch 258 questioning the computation of the association dues and seeking accounting, damages, annulment of the foreclosure proceedings, and preliminary injunction.
- Petitioner moved to dismiss for lack of jurisdiction claiming exclusive jurisdiction of HLURB; RTC denied motion and declared petitioner in default for failure to answer.
- Petitioner petitioned the CA for certiorari, prohibition, and mandamus, arguing forum shopping, litis pendencia (pendency of related cases), and that the prior CA decision already sustained the validity of the auction sale.
- CA First Division denied the petition, ruling the complaint was an intra-corporate controversy under Securities Regulation Code and subject to RTC jurisdiction; motion to dismiss was a prohibited pleading under Interim Rules governing intra-corporate controversies.
- Petitioner’s motion for reconsideration was also denied, prompting the present petition.
Issues:
- Whether the Court of Appeals erred in refusing to dismiss the Moreno spouses' complaint due to:
- The prior CA decision (involving Salvacion) upholding the validity of the extrajudicial public auction sale of the condominium unit and parking slots owned by Mrs. Moreno;
- Allegations of forum shopping and litis pendencia given the existence of the earlier Salvacion case concerning the same property and issues.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)