Case Digest (G.R. No. 147839) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In City Government of Taguig v. Shoppers Paradise Realty & Development Corp., G.R. No. 246179, decided July 14, 2021 under the 1987 Constitution, the City Government of Taguig (CGT) petitioned for review on certiorari from the Court of Appeals’ dismissal of its petition for certiorari against the Regional Trial Court of Makati, Branch 149 (RTC-Makati) acting as Rehabilitation Court in SP Proc. Case No. M-6075. The rehabilitation proceedings dated from a joint petition filed by Shoppers Paradise Realty & Development Corp. (SPRDC) and Shoppers Paradise FTI Corporation (SPFC) on May 9, 2005, following their financial distress after the 1997 Asian Financial Crisis. They operated the Sunshine Plaza Mall within the Food Terminal, Inc. complex in Taguig City and owed realty taxes to CGT. Pursuant to an October 5, 2006 RTC order, CGT issued new tax declarations making stall owners taxpayers while holding SPRDC and SPFC jointly liable. The rehabilitation court approved a Revised Rehabili Case Digest (G.R. No. 147839) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Rehabilitation Proceedings
- Shoppers Paradise Realty & Development Corp. (SPRDC) and Shoppers Paradise FTI Corp. (SPFC), affiliates engaged in mall development, faced financial distress after the 1997 Asian Financial Crisis.
- They filed a joint Petition for Rehabilitation on May 9, 2005 before RTC-Makati (SP Proc. Case No. M-6075). The City Government of Taguig (CGT) was among their creditors for unpaid realty taxes.
- Offsetting Scheme with the CGT
- October 5, 2006 RTC order directed CGT to issue tax declarations to mall tenants but hold SPRDC/SPFC jointly liable for taxes. CGT issued new tax declarations on May 30, 2007.
- November 7, 2006 RTC resolution approved SPRDC/SPFC’s Revised Rehabilitation Plan, envisioning funding tax liabilities through mall lease rentals.
- October 29, 2007 MOA: SPFC leased unoccupied mall units to CGT; rentals credited against realty tax arrears with automatic renewal if CGT stayed in possession. December 5, 2007 Addendum modified lease term and area.
- CGT also occupied additional mall areas for its One-Stop Local Government Center (OSLGC) under EO 32 (2005). A 2009 Booking Term Sheet (BTS) and related letters documented lease terms, though no formal MOA for OSLGC. CGT internal memos in 2015 acknowledged closing of “Area 3 Satellite Office” and directed final account.
- Proceedings Leading to Urgent Motion
- SPFC, believing its tax liabilities offset, demanded CGT payments in August and September 2015; CGT rejected offsets beyond 2006 and disavowed BTS authority.
- Rehabilitation Receiver’s reports (Sept. 22 and Oct. 7, 2015) recommended reconciliation of rentals, utilities, and tax offsets; RTC-Makati ordered reconciliation, but CGT failed to cooperate.
- SPFC paid taxes under protest (Oct. 27, 2015) and filed Urgent Motion for Collection (Nov. 5, 2015) for P10,335,208.84 representing unpaid rentals, utilities, interest, and penalties. CGT opposed, arguing lack of jurisdiction.
- RTC-Makati Order and CA Proceedings
- December 8, 2015 RTC-Makati Branch 149 granted SPFC’s motion, ordering CGT to pay P10,335,208.84 within 15 days.
- CGT filed certiorari before CA (CA-G.R. SP No. 143723), invoking Steel Corporation v. Mapfre Insoluble Ins. Corp. to argue lack of jurisdiction.
- August 28, 2018 CA Decision affirmed the RTC order, holding the claims were within rehabilitation court powers and Steel Corporation inapplicable. March 18, 2019 CA Resolution denied reconsideration.
- Petition for Review on Certiorari
- CGT elevated the case to the Supreme Court via Rule 45 petition (May 14, 2019), reiterating jurisdictional challenge.
- SPRDC/SPFC filed Comment (Aug. 30, 2019); CGT filed Reply (Jan. 23, 2020).
Issues:
- Whether the RTC-Makati, acting as a rehabilitation court, had jurisdiction to grant SPFC’s Urgent Motion for Collection.
- Whether the CA committed reversible error in affirming the RTC’s Order dated December 8, 2015.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)