Case Digest (G.R. No. 211485) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Magallanes Watercraft Association, Inc. v. Auguis and Basnig, G.R. No. 211485, decided on May 30, 2016, petitioner Magallanes Watercraft Association, Inc. (MWAI) is a local association of motorized banca owners operating between Magallanes, Agusan del Norte, and Butuan City. Respondents Margarito C. Auguis and Dioscoro C. Basnig served as vice-president and secretary of MWAI, respectively. On December 5, 2003, MWAI’s Board of Trustees adopted Resolution No. 1, Series of 2003, and issued Memorandum No. 001 suspending Auguis’s and Basnig’s membership rights for thirty days due to unpaid dues amounting to ₱4,059.00 and ₱7,552.00 and their demand for a financial audit. After respondents still failed to settle their obligations, MWAI issued Memorandum No. 002, Series of 2004, imposing an additional thirty-day suspension. On February 6, 2004, respondents sought damages, attorney’s fees, and a preliminary injunction before the Regional Trial Court (RTC) of Butuan City. In its Januar Case Digest (G.R. No. 211485) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Corporate Background
- Petitioner Magallanes Watercraft Association, Inc. (MWAI) is an association of motorized-banca owners/operators.
- Respondents Margarito C. Auguis (vice-president) and Dioscoro C. Basnig (secretary) are MWAI members/officers.
- Suspension of Membership Rights
- December 5, 2003: MWAI Board issued Resolution No. 1 and Memorandum No. 001, suspending respondents’ membership privileges for 30 days due to unpaid dues (Auguis – ₱4,059; Basnig – ₱7,552).
- January 8, 2004: MWAI issued Memorandum No. 002, imposing an additional 30-day suspension for continued nonpayment.
- Judicial Proceedings
- February 6, 2004: Respondents filed a damages suit with prayer for preliminary injunction in RTC, Branch 33, Butuan City.
- January 11, 2007 RTC Decision: Ordered respondents to pay dues; held MWAI liable for actual damages and attorney’s fees.
- March 14, 2013 CA Decision: Affirmed with modification—deleted actual damages, awarded temperate damages (₱40,000 to Basnig; ₱20,000 to Auguis), 12% interest, and reduced attorney’s fees (₱30,000).
- January 17, 2014 CA Resolution: Denied MWAI’s motion for reconsideration. MWAI filed Rule 45 petition before the Supreme Court.
Issues:
- Authority to Suspend
- Whether MWAI’s Board acted ultra vires in suspending respondents’ membership and berthing rights.
- Entitlement to Damages and Fees
- Whether respondents are entitled to temperate damages and attorney’s fees arising from the suspension.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)