Case Digest (G.R. No. 146807) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Padcom Condominium Corporation v. Ortigas Center Association, Inc., decided on May 9, 2002, petitioner Padcom Condominium Corporation (PADCOM) owns and manages the Padilla Office Condominium Building in Ortigas Center, Pasig City. The land was first sold by Ortigas & Company, Limited Partnership (OCLP) to Tierra Development Corporation (TDC) on September 4, 1974, under a deed of sale containing a covenant requiring automatic membership in any future real estate owners’ association in Ortigas Center. TDC transferred the lot, with this covenant duly annotated on the Torrens title, to PADCOM on February 25, 1975. In 1982, respondent Ortigas Center Association, Inc. was organized to represent owners and long-term lessees in Ortigas Center. The Association billed PADCOM for monthly membership dues amounting to ₱2,724.40 from April 1983 to June 1993, accruing to ₱639,961.47 in dues, interest, and penalties. Repeated demands, extension requests, and a settlement proposal ensued, but... Case Digest (G.R. No. 146807) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Property and Covenant
- Padcom Condominium Corporation (PADCOM) owns and manages the Padilla Office Condominium Building in Ortigas Center, Pasig City.
- Tierra Development Corporation (TDC) acquired the land from Ortigas & Company, Limited Partnership (OCLP) under a Deed of Sale dated 4 September 1974, containing a covenant “G. AUTOMATIC MEMBERSHIP WITH THE ASSOCIATION” requiring the owner and its successors to join the future Ortigas Center Association, with dues constituting a lien junior only to government taxes.
- TDC conveyed the lot and improvements to PADCOM by Deed of Transfer dated 25 February 1975, expressly binding PADCOM to all encumbrances annotated on the Transfer Certificate of Title No. 457308, including the automatic-membership provision.
- Formation of the Association and Dues Dispute
- In 1982, Ortigas Center Association, Inc. (the Association) was organized to advance the welfare of property owners and long-term lessees in Ortigas Center.
- The Association demanded monthly membership dues of ₱2,724.40 from PADCOM; corporate records showed arrears amounting to ₱639,961.47 plus interests and penalties from April 1983 to June 1993.
- Repeated demands, extension requests, and a proposed settlement scheme were exchanged, but PADCOM never paid.
- Procedural History
- The Association filed Civil Case No. 63801 for collection of sum of money; PADCOM demurred to the evidence, arguing no automatic membership and no board-approved dues resolution, and invoked freedom of association.
- The Regional Trial Court of Pasig City, Branch 264, dismissed the complaint on 1 September 1997.
- On 30 June 2000, the Court of Appeals in CA-G.R. CV No. 60099 reversed and set aside the dismissal, ordering PADCOM to pay ₱639,961.47, ₱25,000 attorney’s fees, and costs.
- PADCOM sought review before the Supreme Court, raising issues on the automatic membership clause and the validity of dues assessments.
Issues:
- Can PADCOM be compelled to join the Ortigas Center Association by virtue of the automatic-membership covenant annotated on its Transfer Certificate of Title and in the Deed of Transfer?
- Is PADCOM liable for membership dues and penalties absent a specific board resolution prescribing the amount of such dues?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)