Case Summary (G.R. No. L-44059)
Petition and Procedural History
• Two ejectment actions (RTC Civil Case Nos. 802-84-C and 803-84-C) filed by the corporation before the Regional Trial Court of Laguna, Branch 37, to recover possession and rent from petitioners.
• RTC ordered petitioners to vacate, pay monthly rentals, and remove an unfinished building (Rebecca) within ninety days.
• Court of Appeals affirmed; motion for reconsideration denied.
• Supreme Court review granted under the 1987 Philippine Constitution.
Assignment I – Piercing the Corporate Veil
• Petitioners contend co-ownership of corporate capital justifies occupancy and urges disregard of corporate personality.
• Supreme Court affirms corporate fiction: the corporation has a juridical personality separate from its stockholders.
• Registered title and improvements belong to the corporation; stock ownership merely represents an aliquot share of corporate assets.
• No evidence of fraud, injustice, or creditor protection requiring veil piercing.
Assignment II – Due Process and Counsel’s Neglect
• Petitioners argue gross negligence of counsel deprived them of their day in court.
• Records show multiple notices of hearings and clear warnings that failure to appear would result in submission of cases for decision.
• Petitioners and counsel repeatedly missed scheduled hearings despite actual receipt of notices.
• Supreme Court upholds that the client is bound by counsel’s omissions absent extraordinary circumstances; no deprivation of due process.
Assignment III – Builder in Good Faith and Unfinished Building
• Rebecca Boyer-Roxas financed construction of an unfinished building on corporate land with corporate knowledge but without an explicit contract.
• Under Articles 448 and 453 of the Civil Code, a good-faith builder on another’s land is entitled to either:
– Indemnity for improvements if the owner appropriates the building, or
– Reasonable rent or the option to pay for
Case Syllabus (G.R. No. L-44059)
Facts of the Case
- In December 1962 the Heirs of Eugenia V. Roxas, Inc. (“the corporation”) was organized to manage lands inherited from Eugenia V. Roxas and Eufrocino Roxas; in 1971 its purpose was amended to include resort operations.
- The corporation developed Hidden Valley Springs Resort in Barangay Limao, Calauan, Laguna, constructing cottages, pools, a tennis court, a restaurant, pavilions, and several houses.
- Rebecca Boyer-Roxas occupied a staff house near the Balugbugan pool; she and her husband Eriberto Roxas also began building an unfinished house on corporate land.
- Guillermo Roxas occupied a former recreation hall near the tennis court, converted into a residence with corporate funds and materials left by a film producer.
- Both petitioners never paid rent, claimed they were co-owners by virtue of stockholdings, and ignored demands to vacate.
Procedural History
- 1984: Corporation filed RTC Civil Case No. 802-84-C (against Rebecca) and No. 803-84-C (against Guillermo) for ejectment, unpaid rent, removal of improvements, and costs.
- RTC Laguna, Branch 37: respondent presented evidence; petitioners and counsel repeatedly failed to appear at scheduled hearings (July 21, August 11, September 29, October 22, 1986) despite actual notice; on October 22, 1986, the court considered the cases submitted for decision.
- January 15, 1987: RTC rendered judgment ordering eviction, P300 monthly rent from September 10, 1983, until vacation, removal of Rebecca’s unfinished house within 90 days, P100 monthly rent for the unfinished house until removal, and costs.
- Petitioners appealed; the Court of App