Case Digest (G.R. No. 191525)
Facts:
International Academy of Management and Economics v. Litton and Company, Inc., G.R. No. 191525, December 13, 2017, First Division, Sereno, C.J., writing for the Court. Petitioner International Academy of Management and Economics (I/AME) sought review of the Court of Appeals (CA) Decision dated 30 October 2009 and its Resolution of 12 March 2010 affirming the Regional Trial Court (RTC) of Manila’s reversal of a Metropolitan Trial Court (MeTC) order that had cancelled annotations of levy on a TCT and quashed a writ of execution in favor of private respondent Litton and Company, Inc. (Litton).The underlying dispute began with a MeTC unlawful detainer judgment (dated 2 March 1983) in favor of Litton against Atty. Emmanuel T. Santos, the lessee of two buildings owned by Litton, for rental arrears and unpaid realty taxes. The MeTC judgment was not executed immediately; Litton obtained revival of judgment in the RTC (decision dated 13 September 1989) and the CA affirmed (CA decision 21 February 1994), the CA ruling becoming final and executory on 22 March 1994.
On 11 November 1996 the MeTC sheriff levied on a Makati parcel (TCT No. 187565) then registered in the name of I/AME, with annotations noting levy “only up to the extent of the share of Emmanuel T. Santos.” I/AME moved to lift the annotations on the TCT, asserting its separate corporate personality; the MeTC initially denied the motion (Order dated 29 October 2004), but on reconsideration the MeTC reversed itself and ordered cancellation of the annotations and the writ of execution. Litton appealed to the RTC, which reversed the MeTC’s reconsideration and reinstated the original 29 October 2004 MeTC Order. I/AME petitioned the CA, which denied relief and affirmed that the trial courts did not commit grave abuse in piercing the corporate veil.
Dissatisfied, I/AME filed a petition for review on certiorari under Rule 45 in the Supreme Court, arguing denial of due process because it was not impleaded in the main case and arguing the doctrine of piercing the corporate veil does not apply to non‑stock, non‑profit corporations. The CA had found that Santos used I/AME to shield the Makati property from execution (noting, among other facts, misrepresentatio...(Pro-only)
Issues:
- Was I/AME denied due process when the courts pierced its corporate veil and subjected its property to a writ of execution in satisfaction of a judgment against Emmanuel T. Santos?
- Can the doctrine of piercing the corporate veil be applied to a non‑stock, non‑profit corporation like I/AME?
- May the corporate veil be pierced as to natural persons and by “reverse piercing” (i.e., to subject corporate assets to satisfy an individual’s liabil...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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