G.R. No. 98431 - People vs. Dela Torre

In 1974, Multi-Realty Development Corporation (Multi-Realty) constructed the 26-storey Makati Tuscany condominium (160 units). Ordinary units (floors 2–25) numbered 156; penthouses on the 26th floor numbered 4.
The project included 270 parking slots: one per ordinary unit, two per penthouse, eight guest slots, and 98 slots intended for retention by Multi-Realty.
On July 30, 1975, Multi-Realty executed the Master Deed and Declaration of Restrictions, registered in 1977; pursuant to R.A. No. 4726, it incorporated Makati Tuscany Condominium Corporation (MATUSCO) and transferred all “common areas” (including the 98 slots) by Deed of Transfer.

Believing it retained the 98 slots, Multi-Realty sold 26 slots between 1977 and 1986; MATUSCO did not object and even issued Certificates of Management for sold slots. MATUSCO’s board minutes of June 14, 1979 recount offers to purchase unassigned slots from Multi-Realty. Petitioner first asserted ownership over the remaining slots in September 1989.
On April 26, 1990, Multi-Realty filed for damages and reformation of the Master Deed (Civil Case No. 90-1110, RTC Branch 59, Makati), alleging that only eight slots were meant as common guest parking.
The RTC dismissed the complaint (Oct. 29, 1993), finding no mistake and ruling Multi-Realty estopped by deed. Both parties’ appeals were dismissed by the CA on prescription grounds (Aug. 21, 2000).
The Supreme Court granted review (G.R. No. 146726, June 16, 2006), set aside the CA decision, held prescription had not run, and remanded the case.
The CA denied appeals on the merits (Nov. 5, 2007), then in an Amended Decision (Apr. 28, 2008) ordered reformation of the Master Deed and Deed of Transfer to exclude the 98 slots. MATUSCO’s motion for reconsideration was denied (Dec. 4, 2008).
MATUSCO filed the present Petition for Review on Certiorari (Feb. 5, 2009), contending no basis for reformation and that factual findings in the 2006 SC decision are conclusive.

Whether the Master Deed and Deed of Transfer should be reformed to exclude the 98 parking slots from the common areas.
Whether the factual findings in Multi-Realty Development Corporation v. The Makati Tuscany Condominium Corporation (524 Phil. 318, 2006) are conclusive under res judicata.