G.R. No. 143171 - Philippine Long Distance Telephone Co. vs. Tolentino

In April 1979, Rogelio (Roger) Panotes, then president of the Provident Village Homeowners Association, Inc., filed a complaint with the National Housing Authority (NHA) against Provident Securities Corporation (PROSECOR), the owner-developer of Provident Village in Marikina City.
The complaint, docketed as NHA Case No. 4175, alleged violations of Sections 19, 20, 21, 38, and 39 of Presidential Decree No. 957, particularly highlighting the failure to provide an open space in the subdivision.

An ocular inspection during the NHA proceedings revealed that the subdivision had no designated open space.
The NHA identified Block 40, covering an area of 22,916 square meters, as a potential open space.
On August 14, 1980, the NHA issued a Resolution directing PROSECOR to dedicate Block 40 as the open space for Provident Village.
Concurrently, a letter from the then NHA Acting General Manager reinforced the directive to use Block 40 as the mandated open space.
PROSECOR was formally served copies of both the Resolution and the accompanying letter on August 22, 1980, rendering the directive final and executory due to the absence of any appeal from PROSECOR.

At a later stage, PROSECOR sold several lots within Provident Village, including those comprising Block 40, to City Townhouse Development Corporation (CTDC).
CTDC, as the buyer, was unaware of the NHA Resolution concerning the open space requirement.
Leadership of the Provident Village Homeowners Association eventually passed from Panotes to Araceli Bumatay.
On July 17, 1990, Bumatay (as successor-in-interest) filed a complaint with the Housing and Land Use Regulatory Board (HLURB) for the revival of the NHA Resolution.

The HLURB, through Arbiter Charito M. Bunagan on October 15, 1991, ruled in favor of Bumatay by reviving the NHA Resolution, declaring Block 40 as the legally mandated open space for Provident Village.
The HLURB ordered that the Register of Deeds for Marikina annotate the Torrens Title of Block 40 to indicate its reserved status for open space under the applicable provisions of PD No. 957 and PD No. 1216.
A Cease and Desist Order was issued against both PROSECOR and CTDC to prevent any further acts of dominion over Block 40.

CTDC filed an appeal to the Office of the President (OP) following denial of a motion for reconsideration by the HLURB, with the OP affirming the HLURB judgment on February 10, 1999.
CTDC subsequently filed a petition for review with the Court of Appeals (CA) under Rule 43 of the 1997 Rules of Procedure, which was initially dismissed for technical deficiencies but later reinstated upon filing a motion for reconsideration.
On January 29, 2002, the Court of Appeals pronounced a Decision reversing the OP judgment and dismissing the complaint for revival of judgment.

Whether the NHA Resolution dated August 14, 1980, which directed PROSECOR to provide Block 40 as an open space, may be enforced against CTDC.

Is CTDC, as a purchaser of Block 40 from PROSECOR, bound by the NHA Resolution despite not being the original owner-developer?
Can CTDC be considered the successor-in-interest of PROSECOR with regard to the open space obligation mandated under the applicable Presidential Decrees?

Whether an action for revival of judgment, intended solely as an execution device for a previously rendered decision, can extend its binding effect to a third-party buyer like CTDC who was never a party to the original litigation between Panotes and PROSECOR.