Case Digest (G.R. No. 126102) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ortigas & Co., Ltd. v. Court of Appeals and Ismael G. Mathay III, decided on December 4, 2000, the petitioner, Ortigas & Co., Ltd., sold on August 25, 1976, a 1,508-square-meter parcel in Greenhills Subdivision IV, San Juan, Metro Manila (TCT No. 0737) to Emilia Hermoso under a deed of sale that imposed restrictive covenants: the lot was to be used exclusively for single‐family residential purposes, no advertising signs were permitted, building plans required seller approval, and restrictions would run with the land until December 31, 2025. These covenants were annotated on the Torrens title. In March 1981, the Metropolitan Manila Commission enacted MMC Ordinance No. 81-01, reclassifying portions of Ortigas Avenue—including the subject lot—as a commercial zone. On June 8, 1984, private respondent Mathay III leased the lot from Hermoso and J.P. Hermoso Realty Corp. without specifying lease purposes and erected a single‐story commercial building for Greenhills Autohaus, Inc. In Case Digest (G.R. No. 126102) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract of Sale and Restrictive Covenants
- On August 25, 1976, Ortigas & Company Ltd. (petitioner) sold Lot 1, Block 21, Psd-66759 (1,508 sqm) in Greenhills Subdivision IV, San Juan, Metro Manila, covered by TCT No. 0737, to Emilia Hermoso.
- The deed of sale imposed real covenants, annotated on the title, restricting the lot to single-family residential use, prohibiting signs/billboards, requiring seller’s approval of building plans, and providing termination of restrictions on December 31, 2025.
- Zoning Ordinance and Lease
- In 1981, the Metropolitan Manila Commission enacted MMC Ordinance No. 81-01, reclassifying a portion of Ortigas Avenue (including the lot) from residential to commercial use.
- On June 8, 1984, Ismael G. Mathay III (private respondent) leased the lot from Emilia Hermoso and J.P. Hermoso Realty Corp. (10% owner) and constructed a single-story commercial building for Greenhills Autohaus, Inc.
- Trial Court Proceedings
- On January 18, 1995, petitioner filed Civil Case No. 64931 in RTC Pasig (Branch 261) for demolition of the commercial structure and sought a TRO and writ of preliminary injunction. The complaint was amended to implead Mathay III.
- On June 16, 1995, the RTC issued the writ of preliminary injunction. Mathay III moved to set it aside on June 29, 1995; the trial court denied the motion.
- Court of Appeals and Supreme Court Actions
- Mathay III filed CA-G.R. SP No. 39193 (special civil action for certiorari), alleging grave abuse of discretion by the RTC for not applying MMC Ordinance No. 81-01.
- On March 25, 1996, the Court of Appeals granted the petition, nullifying the injunction. It denied Ortigas’s motion for reconsideration on August 13, 1996.
- Ortigas filed a petition for review on certiorari before the Supreme Court, challenging (a) the CA’s application of the zoning ordinance over deed restrictions, (b) Mathay III’s standing, and (c) alleged unaddressed factual issues.
Issues:
- Applicability of Zoning Ordinance to Existing Deed Restrictions
- Whether the Court of Appeals erred in holding that MMC Ordinance No. 81-01 nullified the exclusive residential-use covenants and that the RTC gravely abused its discretion in refusing to apply the ordinance.
- Locus Standi of Lessee
- Whether private respondent Mathay III, as lessee and not owner, is a real party in interest entitled to question the validity of the deed restrictions and to seek dissolution of the injunction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)