Case Digest (G.R. No. 204803) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Grace Christian High School v. Court of Appeals, G.R. No. 108905, decided on October 23, 1997, the petitioner, Grace Christian High School (an educational institution in Grace Village, Quezon City), sought to compel respondent Grace Village Association, Inc. (an organization of lot owners, lessees, and residents) to recognize its representative as a permanent director on the Association’s eleven-member board. From 1975 until 1989, the petitioner’s representative had sat on the board by virtue of an unratified 1975 draft amendment to the Association’s by-laws, which provision was never approved by the general membership or registered with the Securities and Exchange Commission (SEC). On February 13, 1990, the Association’s Committee on Election notified the petitioner that it would no longer tolerate unelected directors and would revert to the original 1968 by-laws requiring election of all directors. The petitioner filed for mandamus before the Home Insurance and Guaranty Cor Case Digest (G.R. No. 204803) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Organizational Background
- Petitioner Grace Christian High School (GCHS) is an educational institution in Grace Village, Quezon City.
- Respondent Grace Village Association, Inc. (GVA) is a non-stock homeowners’ association; respondents Beltran and Go were its president and election committee chair in 1990.
- By-laws and Proposed Amendment
- The original by-laws (adopted 1968, registered with SEC January 16, 1969) provided for an 11-member Board of Directors elected annually by secret ballot (Art. IV).
- On December 20, 1975, a GVA Board committee drafted an amendment declaring “GCHS representative is a permanent Director of the ASSOCIATION,” but this draft was never approved by the membership or filed with SEC/HIGC.
- Practice from 1975 to 1989
- GCHS’s representative sat on the Association’s board as a “permanent director” in all elections held during this period.
- No formal member vote ratified the 1975 draft; the board simply “tolerated” the practice.
- 1990 Reexamination and Mandamus Proceedings
- February 13, 1990: GVA election committee notified GCHS principal it would insist on strict compliance with the 1968 by-laws and reexamine the permanent-director practice.
- GCHS filed a mandamus petition with the Home Insurance and Guaranty Corporation (HIGC) to compel recognition of its representative as a permanent director.
- The HIGC hearing officer (June 20, 1990) and HIGC appeals board (September 13, 1990) dismissed the petition, holding the 1975 draft unratified, void, and contrary to law.
- Court of Appeals (February 9, 1993) affirmed: amendment never approved by majority of members, thus no valid change to by-laws.
- GCHS elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Validity of the 1975 Proposed Amendment
- Whether the unsubmitted, unratified draft by-law granting GCHS a permanent board seat became part of the Association’s governing rules.
- Vested Right of Petitioner
- Whether fifteen years of tolerating GCHS’s representative on the board vested a permanent, enforceable right.
- Compliance with Corporate Law
- Whether allowing an unelected member to hold office violates the Corporation Code and the Association’s registered by-laws.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)