Case Digest (G.R. No. 193459) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the consolidated petitions of Bel-Air Village Association, Inc. (BAVA) and certain lot owners—Jose D. and Lutgarda D. Sangalang, Felix C. and Dolores R. Gaston, Jose V. and Alicia R. Briones, and intervenors—against the Intermediate Appellate Court and Ayala Corporation, G.R. Nos. 71169, 74376, 76394, 78182, and 82281 (Dec. 22, 1988), petitioners sought to enforce by specific performance and damages the restrictive easements embedded in the 1957–1960 deeds of sale for lots in Bel-Air Village, Makati, Metro Manila. Each sale, originally by Makati Development Corporation (later merged into Ayala Corporation), carried covenants: compulsory membership in BAVA, residential‐use only, prohibition of commercial advertising, maintenance of grass and servitude for utilities, and enforcement rights vested in BAVA, the developer, or any lot owner. In 1966 Ayala erected a perimeter wall along Jupiter Street to regulate access, rebuilt it after Typhoon Yoling (1970), and again after street Case Digest (G.R. No. 193459) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Nature and Parties
- Five consolidated petitions (G.R. Nos. 71169, 74376, 76394, 78182, 82281) by lot owners and Bel-Air Village Association, Inc. (BAVA) to enforce “deed restrictions” in Bel-Air Village against Ayala Corporation (formerly Makati Development Corporation) and private respondents.
- Petitioners Sangalang, Gaston, Briones purchased residential lots (1960, 1957, 1958) subject to deed restrictions; BAVA intervened and also filed separate suits against other residents.
- Deed Restrictions
- Mandatory membership in BAVA, compliance with its rules, and payment of assessments (with lien rights).
- Use limitations: lots for residential purposes only; no subdivision (except consolidation/re-subdivision with minimum areas); one single-family house; no commercial signs (name plates limited in size); no livestock (only pets); easements for utilities; no immoral/illegal uses; property maintenance.
- Term and enforcement: restrictions effective for 50 years from January 15, 1957 (amendable/cancelable by BAVA vote); enforceable by BAVA, MDC (Ayala), or any lot owner.
- Development of Jupiter Street and Zoning
- Perimeter fence built along commercial block on Jupiter Street in 1966 (rebuilt 1970, 1972) to control access.
- Ayala subdivided/sold commercial lots (north of Buendia Ave.), imposed similar restrictions, granted commercial owners special BAVA membership, communicated building setbacks, parking, traffic rules.
- Makati Ordinance No. 81 (1975) and MMC Ordinance 81-01 (1981) zoned Bel-Air as residential (R-1) and Buendia extension as commercial (C-3), with Jupiter Street as common boundary.
- BAVA installed gates on Jupiter Street (1972); Makati officials ordered opening of several streets (including Jupiter) in 1977; gates removed forcibly by municipal authorities in August 1977; Jupiter Street opened to public traffic.
- With commercial buildings erected (1974–75), portions of the fence inside commercial lots were demolished; commercial owners built their own fences and hired guards.
- Ayala donated Jupiter Street (1978) to BAVA subject to use by members and general public under conditions; Ayala agreed to maintain it for three years.
- Trial Court Decisions and Court of Appeals Reversals
- In G.R. No. 71169, R.T.C. Pasig awarded Sangalangs, intervenors Gaston, Briones, BAVA damages (P400,000–P500,000 each), moral/exemplary damages, attorneys’ fees, and reconstruction of the wall.
- Court of Appeals reversed and dismissed for lack of cause of action, relying on its prior ruling (AC-G.R. No. 66649) that zoning ordinances permitted mixed use and invalidated deed restrictions.
- In the four companion cases (G.R. Nos. 74376, 76394, 78182, 82281), trial courts granted injunctive relief or damages for residential-only violations; appellate courts uniformly reversed based on zoning reclassification and recognized police power.
Issues:
- Liability of Ayala Corporation for removal of the perimeter wall and opening of Jupiter Street.
- Effect of Makati Ordinance No. 81 and MMC Ordinance 81-01 on validity and enforceability of the deed restrictions.
- Enforceability of residential-only restrictions against private respondents who converted lots into commercial establishments.
- Scope of contractual obligations under deed restrictions versus overriding public welfare and police power.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)