Case Digest (G.R. No. 133250)
Facts:
In Sta. Clara Homeowners’ Association through its Board of Directors, Security Guard Capillo, “John Doe,” and Santa Clara Estate, Inc. (petitioners), the Spouses Victor Ma. Gaston and Lydia Gaston (respondents) filed a Complaint for damages with prayer for preliminary and mandatory injunctions and a Temporary Restraining Order before the Regional Trial Court of Bacolod City (Branch 49) on April 1, 1998 (Civil Case No. 98-10217). The respondents alleged they purchased lots in Sta. Clara Subdivision in 1974 without any requirement to join the homeowners’ association. Until March 1998, non-member homeowners were issued “non-member” gate-pass stickers. On three occasions, the respondents’ son, Victor Ma. Gaston, was forced to present his driver’s license before entering the subdivision despite being known to the guards and residing therein. On March 29, 1998, petitioner guards lowered the steel gate bar and demanded identification from Victor, preventing entry. The respondents claimCase Digest (G.R. No. 133250)
Facts:
- Parties and Complaint
- Petitioners: Santa Clara Homeowners Association (SCHA) through its Board of Directors (Arneil Chua, Luis Sarrosa, Jocelyn Garcia, Ma. Milagros Vargas, Lorenzo Lacson, Ernesto Piccio, Dindo Ilagan, Danilo Gamboa Jr., Rizza de la Rama), security guard Capillo, “John Doe,” and Santa Clara Estate, Inc.
- Respondents: Spouses Victor Ma. Gaston and Lydia M. Gaston, residents of San Jose Avenue, Sta. Clara Subdivision, Bacolod City.
- Underlying Allegations
- Respondents purchased their lots in 1974 with no requirement of membership in any homeowners’ association; they remained non-members of SCHA.
- Prior to March 1998, non-member homeowners were issued “non-member” gate-pass stickers; in mid-March 1998, SCHA issued a board resolution restricting stickers to members in good standing.
- Incidents of Alleged Exclusion
- On three occasions in March 1998, respondents’ son was required to show his driver’s license for entry, despite personal recognition.
- On 29 March 1998, respondent Victor Ma. Gaston was barred from entering his residence when guards lowered the gate and demanded his driver’s license for identification. Respondents claimed moral damages from public embarrassment.
- Procedural History
- 3 April 1998: SCHA’s counsel assured the RTC that respondents would have unrestricted access pending motion to dismiss.
- 8 April 1998: Petitioners moved to dismiss for lack of jurisdiction (intra-corporate dispute under RA 580 as amended by EO 535 and PD 902-A before HIGC) and lack of cause of action.
- 6 July 1998 & 17 August 1998: RTC (Branch 49) denied the motion to dismiss, holding no intra-corporate controversy and sufficient cause of action.
- 24 September 1998: Petitioners filed certiorari with the Court of Appeals (CA).
- 31 August 1999: CA (Special 15th Division) dismissed the petition for lack of merit, affirmed RTC orders.
- 11 February 2000: CA denied petitioners’ motion for reconsideration.
- Petitioners elevated the case to the Supreme Court via Petition for Review on Certiorari.
Issues:
- Whether the CA erred in upholding the RTC’s jurisdiction to declare null and void SCHA’s board resolution limiting vehicle stickers to members in good standing.
- Whether private respondents are members of the SCHA.
- Whether the CA erred in not ordering dismissal of the complaint for lack of cause of action.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)