Case Digest (G.R. No. 134269) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1987, spouses Felipe and Mary Anne Alfonso acquired a parcel of land in Ayala Alabang Village covered by TCT No. 149166. That title bore a Deed of Restrictions requiring the property’s exclusive use for a preparatory (nursery and kindergarten) school. In 1989, the Alfonsos opened The Learning Child Center (TLC) offering only nursery and kindergarten classes. In 1991, they expanded operations to include a grade‐school program, the School of the Holy Cross, prompting the Ayala Alabang Village Association (AAVA) and adjacent homeowners to demand cessation of the grade‐school classes and compliance with local zoning laws limiting nurseries and kindergartens to two classrooms. In October 1992, AAVA filed an injunction suit (RTC Makati, Civil Case No. 92-2950). On July 22, 1994, the RTC enjoined the Alfonsos from operating beyond nursery and kindergarten and excess classrooms. On March 1, 1995, the same court, citing Muntinlupa Zoning Ordinance No. 91-39—which reclassified the prop Case Digest (G.R. No. 134269) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Deed of Restrictions and School Operation
- In 1984–1987, Ayala Land, Inc. (ALI) sold Lot 25, Block 3, Phase V, Ayala Alabang Village, to the Yusons and then to the Alfonsos. A deed of restrictions was annotated on TCT No. 149166, limiting the lot “exclusively for the establishment and maintenance of a preparatory (nursery and kindergarten) school,” with related installations.
- In 1989, petitioners The Learning Child, Inc. (TLC) and the Alfonsos opened TLC Pre-School. In 1991 they expanded to include a grade school (School of the Holy Cross), enrolling pupils beyond nursery and kindergarten.
- Injunction Case (RTC → CA → SC)
- October 1992: Ayala Alabang Village Association (AAVA) filed for injunction in the Makati RTC, alleging breach of the deed of restrictions, violation of MMC Ordinance No. 81-01 (limiting nursery/kindergarten to two classrooms), and Barangay Ordinance No. 03 (parking ban on
- July 22, 1994 RTC Decision: enjoined operation of grade school and excess kindergarten classrooms; ordered P20,000 attorney’s fees.
- March 1, 1995 RTC Order on reconsideration: set aside July 1994 Decision due to Muntinlupa Zoning Ordinance No. 91-39 reclassifying the lot as “institutional.”
- November 11, 1997 CA Decision: reinstated July 1994 RTC Decision. July 2, 1998 CA Resolution denied motions for reconsideration and intervenors’ leave.
- Petitions for review on certiorari: G.R. No. 134269 (TLC/Alfonsos) and G.R. No. 134440 (Aquino, et al.).
- Zoning Ordinance Case (HLURB → OP → CA → SC)
- December 1991: Muntinlupa Ordinance No. 91-39 classified the property as institutional. October 3, 1994 Resolution No. 94-179 corrected a “typographical error” in Appendix B, changing “Block 1” to “Block 3.”
- June 26, 1995 HLURB Resolution: treated the correction as rezoning, remanded for public hearings.
- July 27, 1999 Office of the President (OP) Decision: declared Resolution 94-179 a mere correction not requiring hearings; refused to extinguish deed restrictions.
- August 15, 2000 CA Decision (CA-G.R. SP No. 54438): affirmed OP Decision but vacated OP ruling nullifying deed restrictions.
- Petition for review on certiorari: G.R. No. 144518 (AAVA and neighbors).
Issues:
- Validity of Muntinlupa Resolution No. 94-179
- Was it a mere typographical correction not requiring public notice/hearing under MMC Resolution No. 12?
- Could it be challenged despite MMC and MMC-appointed map approvals?
- Intervention of Aquino, et al.
- Was their motion to intervene timely under Section 2, Rule 19, 1997 Rules of Civil Procedure?
- Is their interest moot since they were grade schoolers by 1998?
- Injunction Against Grade School Operation
- Does Ordinance No. 91-39 (as corrected) nullify the deed of restrictions limiting use to preparatory school?
- Are AAVA and ALI estopped from enforcing the deed by alleged prior approvals?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)