Case Digest (G.R. No. 206038) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mary E. Lim, represented by her Attorney-in-Fact, Reynaldo V. Lim, v. Moldex Land, Inc., 1322 Roxas Boulevard Condominium Corporation, et al. (G.R. No. 206038, January 25, 2017), petitioner Lim, a registered unit owner of the Golden Empire Tower condominium, assailed the March 4, 2013 Decision of the Regional Trial Court (RTC) of Manila, Branch 24, in Civil Case No. 12-128478. Lim sought: (a) annulment of the July 21, 2012 Annual General Membership Meeting of the condominium corporation (Condocor); (b) annulment of the election of four individual respondents—Jeffrey Jaminola, Edgardo Macalintal, Joji Milanes, and Clothilda Anne Roman—as members of the Board of Directors; and (c) an accounting. At the July 21 meeting, only 29 of the 108 unit buyers attended. Moldex Land, Inc. (Moldex), as owner of 220 unsold units, parking slots, and storage areas, purportedly supplied a quorum through its voting rights and appointed the individual respondents as its proxies. After Lim’s objec Case Digest (G.R. No. 206038) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Corporate Structure
- Petitioner Mary E. Lim is a registered unit owner of 1322 Golden Empire Tower and a member of 1322 Roxas Boulevard Condominium Corporation (Condocor).
- Respondent Moldex Land, Inc. is the developer and registered owner of 220 unsold units in Golden Empire Tower; Condocor is a non-stock, non-profit corporation of unit owners.
- Individual respondents Jeffrey Jaminola, Edgardo Macalintal, Joji Milanes, and Clothilda Anne Roman were members of Condocor’s Board of Directors since 2008.
- July 21, 2012 Annual General Membership Meeting
- Condocor’s corporate secretary certified a quorum based on the presence of 29 unit-buyer members and proxy votes representing Moldex’s 58,504 voting rights.
- Lim objected to the meeting’s validity; her objection was denied and she, with other unit owners, walked out.
- Despite the walkout, the individual respondents and one other member proceeded to elect a new Board of Directors for 2012–2013.
- Organizational Meeting and Election Protest
- The newly elected board held an organizational meeting: Jaminola was elected Chairman and President; Milanes, Vice-President; Roman, Treasurer; Macalintal, Corporate Secretary; and others as assistant secretaries.
- Lim filed an election protest in the Regional Trial Court (RTC) of Manila, Branch 24, seeking annulment of the July 21 meeting, annulment of the board election, and accounting.
- The RTC dismissed the complaint, ruling that Moldex was a member of Condocor, that its proxies established quorum, and that the individual respondents’ election was valid.
- Proceedings Before the Supreme Court
- Lim filed a petition for review on certiorari under Rule 45 of the Rules of Court.
- The Supreme Court initially denied the petition for wrong mode of appeal (mixed questions of fact and law) but later granted reconsideration, finding that the issues were pure questions of law.
Issues:
- Procedural Issues
- Whether the petition for review under Rule 45 raises pure questions of law permitting direct appeal to the Supreme Court.
- Whether the petition should have been filed with the Court of Appeals due to intra-corporate dispute jurisdiction.
- Substantive Issues
- Whether Lim remains a member of Condocor despite executing a Deed of Assignment in favor of others.
- Whether the July 21, 2012 Annual General Membership Meeting was valid for lack of quorum.
- Whether Moldex can be deemed a member of Condocor.
- Whether non-unit buyers appointed as proxies may be elected as members of Condocor’s Board of Directors and corporate officers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)