Case Digest (G.R. No. 245438) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Frabelle Properties Corporation vs. AC Enterprises, Inc. (G.R. No. 245438, January 16, 2023), petitioner Frabelle Properties Corporation (Frabelle), the developer and manager of the 29-storey Frabella I Condominium in Legaspi Village, Makati City, filed a complaint for abatement of nuisance with damages against respondent AC Enterprises, Inc., owner of the 10-storey Feliza Building located some 12 meters behind Frabella I. Feliza Building’s 36 external air-conditioning blowers, installed from the first to ninth floors, were alleged to generate excessive noise and hot air directed at Frabella I’s rear units, disrupting its tenants and allegedly reducing rental income by 25–30%. Beginning in 1995, Frabelle sent three letters of complaint to AC Enterprises and sought administrative relief from the Pollution Adjudication Board and the Makati City Mayor, to no avail. In July 2003, Frabelle instituted Civil Case No. 3745-MN before the Regional Trial Court (RTC) of Malabon City, Bra Case Digest (G.R. No. 245438) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and properties
- Petitioner Frabelle Properties Corp. is the developer and manager of Frabella I Condominium, a 29-storey residential/commercial building in Makati City; it owns and leases out units.
- Respondent AC Enterprises, Inc. owns Feliza Building, a 10-storey office/commercial building located behind Frabella I; its air-conditioning system features 36 external blowers (four per floor on floors 1–9) facing Frabella I.
- Alleged nuisance and prior complaints
- Petitioner contended since Frabella I’s construction (1995) that respondent’s blowers emitted excessive noise and hot air, constituting a private nuisance to its tenants.
- Petitioner sent letters (1995, 2000), filed administrative complaints with the Pollution Adjudication Board and Makati City Hall (2001–2002), and sought municipal orders to abate noise/pollution.
- Respondent’s remedial measures and noise tests
- In 2000 and 2006, respondent installed soundproofing, replaced blowers and condensers, added rooftop condensers, and rerouted ducts to direct hot air away from Frabella I.
- Various noise readings (MMDA, DENR, MACEA, Makati Health Office) from 1995 to 2008 showed levels both above and below the 65 dB daytime limit; most recent independent tests by IAA Technologies (Nov. 13 & 22, 2008) recorded 61.3–63.4 dB.
- Procedural history
- RTC Malabon City, Branch 74 (Nov. 28, 2014) found a private nuisance, permanently enjoined operation of the 36 blowers, and awarded temperate damages (25–30% loss of rental income), exemplary damages, and attorney’s fees.
- CA (June 19, 2018 Decision; Feb. 18, 2019 Resolution) reversed and set aside the RTC decision, holding petitioner failed to prove actionable nuisance or losses. Petitioner filed a Rule 45 petition before the Supreme Court.
Issues:
- Whether respondent’s air-conditioning blowers constitute an actionable private nuisance.
- Whether petitioner is entitled to temperate and exemplary damages and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)