Case Digest (G.R. No. 180512) Core Legal Reasoning Model
Facts:
The case involves Daalco Development Corporation (petitioner), the developer of Palmas del Mar Subdivision, and Palmas del Mar Homeowners Association (PDM-HOA) represented by its president Gil Fernandez (respondent). On December 8, 2016, PDM-HOA filed a complaint demanding that Daalco donate all open spaces, roads, and parks in the subdivision to the local government of Bacolod City, as mandated by Presidential Decree (PD) No. 1216. PDM-HOA argued that only portions of Lot 4, Block 1, Phase 1 (Lot 4), where the water tank is located, and Road Lot 5B, hosting the underground pipes, were donated by Daalco. PDM-HOA also sought turnover of the ownership and management of the water facilities to the association, citing their right under Republic Act (RA) No. 9904, the Magna Carta for Homeowners and Homeowners’ Associations, to ensure quality water services at reasonable prices.
Daalco contended it complied with the 30% open space requirement, citing a total open space and roads dona
Case Digest (G.R. No. 180512) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Daalco Development Corporation (Daalco), the subdivision developer of Palmas Del Mar Subdivision in Bacolod City.
- Respondent: Palmas del Mar Homeowners Association (PDM-HOA), represented by its President, Gil Fernandez.
- Complaint Filed by PDM-HOA
- On December 8, 2016, PDM-HOA filed a Complaint demanding Daalco to:
- Donate all open spaces, roads, and parks of Palmas Del Mar Subdivision to Bacolod City as required under Presidential Decree (PD) No. 1216.
- Turn over ownership and management of the water facility to PDM-HOA, citing their right under Republic Act (RA) No. 9904 (Magna Carta for Homeowners and Homeowners’ Association).
- PDM-HOA argued that Daalco only donated portions of the subdivision:
- Portions of Lot 4, Block 1, Phase 1 (location of the water tank).
- Road Lot 5B (location of underground water pipes).
- Daalco’s Contentions
- Claimed compliance with the 30% open space requirement under PD No. 1216, donating 38,335 square meters (7,209 sqm open spaces + 31,126 sqm roads) out of 127,142 sqm total project area.
- Argued that PD No. 1216 does not mandate donation of water facilities or pipes.
- Insisted their interests must be considered as the water facilities also serve Palmas del Mar Resort Hotel, which predates the subdivision.
- HLURB Decision (August 3, 2017)
- Ordered Daalco to donate the entire subject properties, including the area occupied by the water system, to Bacolod City.
- Directed turnover of water system management to PDM-HOA after proper consultation with the general membership.
- Held that PD No. 1216 provides no exception to donation of open spaces.
- Relied on Section 10(g) of RA No. 9904 granting PDM-HOA the right to operate the water system.
- HSAC Decision (December 9, 2020)
- Affirmed HLURB’s decision.
- Cited jurisprudence (Liwag v. Happy Glen Loop Homeowners Association, Inc.) holding that the property where water pipes are located comprises open spaces.
- Confirmed PDM-HOA’s right to manage the water system after consultation with membership as per RA No. 9904.
- Court of Appeals Ruling (February 16, 2022)
- Denied Daalco’s petition; upheld donation of Lot 4 to Bacolod City even if more than 30% of the subdivision area is allotted.
- Rejected Daalco’s argument that water system serves both subdivision and Resort.
- Emphasized welfare of residents over Daalco’s business interests.
- Allowed management of waterworks system by PDM-HOA.
- Daalco’s Motion for Reconsideration and Appeal
- Argued the Court’s prior ruling in Republic v. Spouses Llamas grants developers discretion whether or not to donate open spaces.
- Proposed joint ownership/management of water system given dual usage.
- CA denied the motion.
- Issues Raised by Parties
- Daalco contends the CA erred in ordering donation of entire Lot 4 and turnover of water system management.
- PDM-HOA argues the water system land is part of the approved subdivision site plan and cannot be deviated to prejudice buyers.
Issues:
- Whether Daalco is legally compelled to donate the properties occupied by the Palmas del Mar Subdivision water system to Bacolod City under PD No. 1216.
- Whether PDM-HOA has the right to demand turnover of ownership and management of the water system under RA No. 9904.
- Whether the welfare of subdivision residents overrides the developer’s business interests regarding management and donation of the waterworks system.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)