Case Digest (G.R. No. 200150) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Catherine Ching, et al. v. Quezon City Sports Club, Inc., petitioners Catherine and Lorenzo Ching and their daughters Laurence and Christine sued respondent Quezon City Sports Club, Inc. (the Club), its Board of Directors, and Finance Manager Lourdes Ruth M. Lopez for damages after Catherine’s membership privileges were suspended in May 2003. Catherine, a Club member since 1989, was assessed a special fee of ₱2,500 by Board Resolution No. 7-2001 to satisfy an executory NLRC judgment against the Club. This amount was charged in five monthly installments of ₱500 each to Catherine’s monthly statements from September 2001 to January 2002, but she deliberately withheld full payment and instead left a balance of ₱2,500 unpaid through May 2003. Pursuant to Board Resolution No. 3-2002 (April 18, 2002) and a May 22, 2003 memorandum posted for Club personnel, Catherine’s membership and those of her dependents were suspended for nonpayment. Catherine first learned of her suspension when Case Digest (G.R. No. 200150) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Membership
- Petitioners
- Lorenzo and Catherine Ching (spouses) and their children Laurence and Christine Ching.
- Catherine became a member of Quezon City Sports Club, Inc. in 1989; membership extended to immediate family.
- Respondents
- Quezon City Sports Club, Inc. (“Club”).
- Board of Directors: Antonio T. Chua, Margaret Mary A. Rodas, Alejandro G. Yabut, Jr., Robert C. Gaw, Edgardo A. Ho, Romulo D. Sales, Bienvenido Alano, Augusto E. Orosa.
- Finance Manager: Lourdes Ruth M. Lopez.
- Special Assessment and Delinquency
- Labor Judgment and Resolution No. 7-2001 (Sept. 20, 2001)
- Final judgment against Club for illegal dismissal awarded ₱4,433,550.00; writ of execution served Sept. 19, 2001.
- Board Resolution No. 7-2001 imposed a special assessment of ₱2,500.00 per member, payable in five monthly installments of ₱500.00.
- Catherine was notified by letter dated Sept. 25, 2001; statements of account from September 2001 to January 2002 showed ₱500.00 debits and general notices of automatic suspension for past‐due accounts.
- Non-payment and Suspension
- Catherine paid short of full installments from Sept. 2001 to May 2003, leaving a ₱2,500.00 balance.
- Board Resolution No. 3-2002 (Apr. 18, 2002) suspended privileges of members who failed to pay the special assessment.
- On May 22–23, 2003, Laurence and Catherine were refused services; Catherine received copies of Resolutions 7-2001 and 3-2002 and a May 22, 2003 memorandum listing suspended members (her name highlighted and posted).
- Catherine sent a demand letter May 24, 2003; respondents replied May 29, 2003 denying defamation.
- Complaint and Prior Proceedings
- Petitioners filed a complaint for damages on July 7, 2003 citing Articles 19–21, Civil Code.
- Trial evidence: Catherine paid under protest on July 13, 2003; alleged harassment continued; Board Resolution No. 10-2006 expelled Catherine (notice Nov. 20, 2006).
- RTC Decision (May 23, 2008)
- Held assessment valid under business judgment rule; no bad faith in imposition.
- Found violation of By-Laws Section 35(a) in suspension without notice or hearing.
- Awarded moral damages ₱200,000.00, exemplary damages ₱50,000.00, attorney’s fees ₱50,000.00, and costs.
- CA Decision (June 27, 2011)
- Applied By-Laws Section 33(a), allowing automatic suspension upon notice in statements.
- Found no bad faith, hearsay cancels trainer’s testimony; dismissed complaint and counterclaims.
- Petitioners’ Rule 45 petition to the Supreme Court.
Issues:
- Which By-Laws provision governs suspension for non-payment of the special assessment: Section 33(a) (automatic suspension of ordinary bills) or Section 35(a) (suspension after notice and hearing for violation of resolutions)?
- Whether respondents acted in bad faith or with malice in suspending Catherine and posting/highlighting her name.
- Whether the testimony of Roland Dacut regarding instructions to avoid playing with petitioners is hearsay and without probative value.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)