Case Digest (G.R. No. 156052) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1952, Ortigas & Co., Limited Partnership (then Ortigas, Madrigal y Cia), as vendor, and Augusto Padilla y Angeles and Natividad Angeles, as vendees, executed installment‐sale agreements covering Lots Nos. 5 and 6, Block 31 of the Highway Hills Subdivision in Mandaluyong, Rizal. On July 19, 1962, the Angeleses transferred their interests to Emma Chavez, who, upon full payment of the purchase price, received corresponding deeds of sale. Both the installment agreements and the deeds of sale, later annotated on Transfer Certificates of Title Nos. 101509 and 101511, contained restrictive covenants: the land was to be used exclusively for residential purposes; no soil, stones, or gravel were to be removed; any improvement had to meet specified construction, sanitation, and setback requirements. Thereafter, FEATI Bank and Trust Co. acquired Lot 5 directly from Chavez “free from all liens and encumbrances,” and Lot 6 by way of deed of exchange with Republic Flour Mills (whose title l Case Digest (G.R. No. 156052) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Real Estate Development
- Plaintiff-Appellant: Ortigas & Co., Limited Partnership (formerly Ortigas, Madrigal y Cia), engaged in developing and selling residential lots in the Highway Hills Subdivision, Mandaluyong, Rizal.
- Defendant-Appellee: Feati Bank and Trust Co., a Philippine corporation, acquired Lots Nos. 5 and 6 in the same subdivision for banking purposes.
- Original Sale Contracts and Restrictions
- March 4, 1952: Plaintiff sold Lots 5 and 6 on installment to Augusto Padilla y Angeles and Natividad Angeles under contracts stipulating exclusive residential use, prohibition on removal of soil/stones/gravel, and construction requirements (materials, painting, sanitary installations, two-meter setback).
- July 19, 1962: Angeles vendees transferred rights to Emma Chavez; upon full payment, plaintiff executed deeds of sale embodying the same restrictions, which were annotated in Transfer Certificates of Title (“TCT”) Nos. 101509 and 101511.
- Subsequent Transfers and Zoning Resolution
- Defendant acquired Lot 5 from Emma Chavez (TCT No. 101613) and Lot 6 from Republic Flour Mills (TCT No. 106092) “free from liens and encumbrances,” but the original building restrictions remained annotated.
- February 4, 1960: Municipal Council of Mandaluyong Resolution No. 27 declared the area along EDSA from Shaw Boulevard to Pasig River a commercial and industrial zone.
- Construction, Litigation, and Procedural History
- May 5–6, 1963: Defendant commenced construction of a bank building on Lots 5 and 6; plaintiff demanded cessation based on the annotated residential restrictions. Defendant, holding valid municipal building and planning permits, refused.
- Civil Case No. 7706: Plaintiff sought injunction to enforce the restrictions. The Court of First Instance of Rizal dismissed the complaint, ruling that the municipal zoning resolution, as a valid exercise of police power, prevailed over the private restrictions. Motion for reconsideration was denied (March 26, 1965). Plaintiff appealed, raising only questions of law, and the records were elevated directly to the Supreme Court.
Issues:
- Is Municipal Council Resolution No. 27, series of 1960, a valid exercise of police power by the Municipality of Mandaluyong?
- Can said resolution nullify or supersede the building restrictions and contractual obligations embedded in the deeds of sale and annotated in the TCTs held by Defendant-Appellee?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)