Case Digest (G.R. No. 170783) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2004, petitioners Lilia Marquinez Palanca, Rosanna D. Imai, Gloria Domingo and Ray Vincent, as the incumbent Board of Directors of Legaspi Towers 300, Inc., called the annual members’ meeting and election on April 2 at the condominium lobby. Of 5,723 voting members, 1,358 voted by proxy but most proxies were deemed irregular, and for lack of time to authenticate them the Election Committee and the Board declared no quorum and adjourned. A group of unit owners led by respondents challenged that adjournment, held their own count, declared a quorum of 2,938 votes, proceeded with the election and sent to the SEC a General Information Sheet reflecting Amelia P. Muer as President and the rest of respondents as the new Board for 2004-2005. On April 13, 2004, petitioners sued for nullity of elections before the RTC of Manila, filed an Amended Complaint on April 14, and on April 20 moved to admit a Second Amended Complaint adding Legaspi Towers 300, Inc. as plaintiff and prayed for an Case Digest (G.R. No. 170783) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Legaspi Towers 300, Inc., a non-stock condominium corporation, scheduled its 2004 annual meeting and board election for April 2, 2004. Petitioners Lilia Palanca, Rosanna Imai, Gloria Domingo and Ray Vincent were the incumbent board.
- Of 5,723 entitled voters, 1,358 voted by proxy; the Committee on Elections found many proxies irregular. Petitioners adjourned the meeting for lack of a quorum (2,863 votes), but respondents proceeded with the election and submitted their roster to the SEC.
- Procedural History
- On April 13, 2004 petitioners filed a complaint for nullity of the April 2 election with prayers for TRO and preliminary injunction. They filed successive amended complaints and sought a 72-hour ex parte TRO, which Executive Judge Lanzanas granted on April 21, 2004.
- Respondents answered, and the case was raffled to RTC Manila, Branch 3 (Judge De Castro). On April 26, 2004 the court clarified the TRO’s status quo and set pre-trial. Petitioners moved to file a Second Amended Complaint to implead Legaspi Towers 300, Inc. as plaintiff; the trial court denied the motion in two Orders of July 21, 2004, and denied reconsideration on September 24, 2004.
- Petitioners filed a certiorari petition with the CA, which dismissed it in a July 22, 2005 Decision and denied reconsideration in a November 24, 2005 Resolution. Petitioners elevated the case to the Supreme Court.
Issues:
- Whether RTC Judge De Castro committed grave abuse of discretion in denying the admission of the Second Amended Complaint.
- Whether petitioners, as the hold-over board, had the legal basis to implead Legaspi Towers 300, Inc. as plaintiff in a direct action.
- Whether the 2005–2006 board election mooted the controversy.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)