Case Digest (G.R. No. 141961)
Facts:
Sta. Clara Homeowners Association thru its Board of Directors et al. v. Spouses Victor Ma. Gaston and Lydia Gaston, G.R. No. 141961, January 23, 2002, Supreme Court Third Division, Panganiban, J., writing for the Court.Petitioners are Sta. Clara Homeowners Association (SCHA) thru its Board of Directors, individual board members, a security guard and Santa Clara Estate, Inc.; respondents are spouses Victor Ma. Gaston and Lydia M. Gaston (private respondents). The Gastons filed a complaint for damages with prayer for preliminary injunction/mandatory injunction and temporary restraining order against petitioners in the Regional Trial Court (RTC), Negros Occidental, Bacolod City (Civil Case No. 98-10217, raffled to Branch 49). The Gastons alleged they bought lots in Sta. Clara Subdivision in 1974, never became members of SCHA, and that beginning in March 1998 SCHA enforced a board resolution issuing vehicle stickers only to members in good standing; on several occasions their son was required to show his driver’s license and on 29 March 1998 he was prevented from entering the subdivision by guards, causing humiliation and alleged moral damage.
During the RTC hearing on a temporary restraining order, petitioners’ counsel said a motion to dismiss would be filed and promised unrestricted access pending disposition. Petitioners thereafter filed a motion to dismiss arguing lack of jurisdiction because the controversy was intra-corporate and thus cognizable by the Home Insurance (and Guaranty) Corporation (HIGC) under Republic Act No. 580 as amended (and implementing rules), asserting that SCHA’s Articles of Incorporation and by‑laws made all subdivision landowners automatic members. The RTC denied the motion to dismiss on 6 July 1998, finding no intra‑corporate controversy because the complaint alleged the Gastons were not members; petitioners’ motion for reconsideration was denied on 17 August 1998. Petitioners renewed the lack‑of‑cause‑of‑action ground; the RTC again denied dismissal on 8 September 1998. On September 24, 1998 petitioners elevated the matter to the Court of Appeals (CA) by petition for certiorari.
The Court of Appeals (Special Fifteenth Division, penned by Sabio, Jr., J., concurred by Reyes and Amin, JJ.) dismissed petitioners’ certiora...(Subscriber-Only)
Issues:
- Did the RTC have jurisdiction to entertain the Gastons’ complaint (i.e., was the controversy an HIGC/HLURB intra‑corporate matter)?
- Did the complaint state a cause of action such that it was not dismissible for lack of cause of action?
- Were private respondents members of SCHA (such that HIGC/HLURB jurisdiction or dismis...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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