G.R. No. 191525 - International Academy of Management and Economics vs. Litton and Co., Inc.

Atty. Emmanuel T. Santos (Santos) leased two buildings from Litton and Company, Inc. (Litton) but defaulted on rental arrears and realty taxes.
Litton sued Santos for unlawful detainer before the Metropolitan Trial Court (MeTC) of Manila, which ruled in Litton’s favor, ordering Santos to vacate the premises and pay arrears, taxes, penalties, and attorney’s fees.
The MeTC judgment was not executed; Litton secured revival of judgment from the Regional Trial Court (RTC), which was affirmed by the Court of Appeals (CA). The CA decision became final and executory on 22 March 1994.

On 11 November 1996, the MeTC sheriff levied on a Makati property covered by TCT No. 187565 registered in the name of International Academy of Management and Economics, Inc. (I/AME), but annotated “only up to the extent of the share of Emmanuel T. Santos.”
I/AME, asserting separate corporate personality, moved to lift the levy annotations, which MeTC denied on 29 October 2004; upon reconsideration, MeTC canceled the annotations and writ of execution.

Litton appealed the cancelation order to the RTC, which reinstated the original MeTC order denying I/AME’s motion to lift annotations.
I/AME petitioned the CA, which denied relief, holding that Santos used the corporate veil of I/AME to shield his property during the pendency of appeals and that the Deed of Absolute Sale (31 August 1979) falsely represented Santos as I/AME’s President before its incorporation in 1985.
The CA found that TCT No. 187565 was issued only in November 1993, years after the sale and incorporation, evidencing fraudulent use of I/AME as a shield against execution.

Whether due process of law was violated when the courts pierced I/AME’s corporate veil and subjected its property to execution on Santos’s liability.
Whether the doctrine of piercing the corporate veil, including reverse piercing, applies to non-stock corporations and to natural persons acting as alter egos.