Case Summary (G.R. No. 83358)
Legal and Factual Background
The dispute centers on a Deed of Restrictions annotated on Cariday’s property title in Forbes Park, which prohibits more than one "single-family residential building" on a lot and requires that lots be used solely for residential purposes. The FPA enforces these restrictions through its rules, including prohibitions against commercial use and occupancy by multiple unrelated families. The petitioner Cariday renovated its building in 1986–1987, altering its structure internally to accommodate two families. Cariday leased portions of the building to two separate tenants, prompting FPA to enforce restrictions by denying tenant entry and threatening to disconnect water service supplied by the association.
Provisions Governing the Restrictions
The Deed of Restrictions and FPA’s Articles of Association provide that:
- Only one single-family residential building may be constructed per lot, with allowance solely for auxiliary structures like servants' quarters and garages.
- Lots may be used only for residential purposes, excluding commercial, business, or office uses such as hotels, motels, resorts, condominiums, stores, or clubs.
- Use and occupancy are limited to owners, bona fide residents, family members, guests, and domestic staff, barring commercial tenants.
- The FPA may disconnect water service to enforce breach of restrictions, after due written notice.
Proceedings and Lower Court Decisions
Cariday sought injunctive relief in the Regional Trial Court to prevent FPA from disconnecting water and restricting tenant ingress, alleging that its leasing activities complied within its rights. The trial court granted a preliminary injunction in favor of Cariday. Upon appeal, the Court of Appeals annulled the injunction, siding with FPA's authority to enforce the single-family occupancy rule and to disconnect water service for violations, holding that:
- The term “one single-family residential building” means a single family’s occupancy,
- Leasing to multiple unrelated families violates subdivision restrictions,
- FPA's rules and actions fall within the power granted by Deed of Restrictions and association rules.
Supreme Court’s Majority Ruling
The Supreme Court, applying the 1987 Constitution and focusing on the plain language of the restrictions, upheld the Court of Appeals’ interpretation, holding that:
- The restriction limits not only the physical number of buildings but also restricts occupancy to one single family per building.
- The purpose of these restrictions is to prevent overcrowding, protect common facilities, preserve aesthetics, tranquility, and security in a prestigious residential community.
- Permitting separate families to reside in one building, even if outwardly a single-family home, circumvents the intended restriction.
- The concept of single-family may include an extended family residing together but excludes leasing to unrelated tenant families.
- Enforcement measures, including disconnection of water service and refusal of tenant entry, are legitimate powers of the FPA to ensure compliance.
Therefore, Cariday’s petition was denied, with costs.
Dissenting Opinion: Justice Gutierrez, Jr.
Justice Gutierrez dissented, emphasizing a liberal and reasonable interpretation of property rights and contractual restrictions. He reasoned:
- No showing proves that two families residing in one large house causes overcrowding or deterioration the restriction seeks to prevent.
- The restrictive enforcement aims more at preserving real estate values and an elitist lifestyle rather than public welfare or aesthetics.
- The 1987 Constitution’s social justice and human rights provisions mandate rational land use and equitable access to housing, which are undermined by such restrictive enforcement.
- Restrictions on property must be reasonable; courts should resist validating overly rigid controls that exacerbate social inequality.
Gutierrez called for granting the petition to relax occupancy restrictions in favor of practicality and social policy.
Dissenting Opinion: Justice Medialdea
Justice Medialdea, also dissenting, focused on the textual and legal interpretation of the restriction:
- The phrase “one single-family residential building” specifies the type and number of structures allowed, not the use or number of occupants after construction.
- A distinct provision regulates use and occupancy, restricting commercial uses but not explicitly limiting occupancy to one family.
- Courts should resolve doubts in favor of property owners’ rights, especially when restrictions are not explicit.
- Leasing to multiple families should be allowed if the building conforms externally to the single-family home type and is used solely for residential—not commercial—purposes.
- The cited case law and FPA’s own rules indicate that occupancy restrictions exist only for commercial purposes, not occupancy by unrelated families.
- Imposing occupancy limits can produce absurd results, such as banning families’ relatives from residing together.
He argued for granting the petition and relieving Cariday from FPA’s occupancy enforcement.
Applicable Legal Principles and Societal Considerat
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Case Syllabus (G.R. No. 83358)
Facts and Background
- Cariday Investment Corporation ("Cariday") owns a residential building in Forbes Park Subdivision, making it a member of Forbes Park Association, Inc. ("FPA"), a non-stock, non-profit corporation representing residents and lot owners.
- The Deed of Restrictions annotated on Cariday's land title (TCT No. S-91329) and reflected in FPA’s rules and regulations restricts the use of lots to residential purposes with "not more than one single family residential building" constructed on each lot.
- The Deed of Restrictions also imposes easements for public facilities and prescribes that separate servant’s quarters and certain outbuildings are permissible.
- FPA’s rules elaborate that one residential building per lot is allowed, intended exclusively for the owner’s residence or bona fide residents, prohibiting commercial uses or multi-family occupancy.
- In June 1986, Cariday made structural repairs to its building; subsequent inspections revealed modifications permitting occupancy by more than one family—violating the "single-family" restriction.
- Cariday leased portions of its building to two unrelated tenants, an Englishman and an American executive, after notifying FPA and attempting to secure clearances.
- FPA denied entry to the second tenant and threatened to disconnect water service supplied by its deep-well pumps for violations of the restrictions.
- Cariday sought a preliminary injunction from the Regional Trial Court of Makati to prevent FPA from cutting water and barring tenant access, citing harm to tenants.
- The trial court issued the injunction, but upon FPA’s appeal, the Court of Appeals annulled it, upholding FPA’s authority to enforce the restrictions, including water disconnection.
Legal Issue
- The core legal question is the proper interpretation of the restriction limiting the construction and use of property to "one single-family residential building” on each lot within Forbes Park.
- Specifically, whether the restriction prohibits multiple unrelated families from occupying a building designed as a single residential unit or whether it applies only to the number and style of buildings but not their internal use or occupancy.
Deed of Restrictions and Association Rules
- The restrictive covenant on the title mandates:
- Lots may only be used for residential purposes.
- Only one single-family residential building may be constructed per lot.
- Separate servants’ quarters and garage/bathhouses for swimming pools are exceptions.
- The FPA’s Rules and Regulations further specify:
- One residential building per lot is permitted, strictly for residential use by owners, bona fide residents, house guests, staff, and domestics.
- Commercial use is expressly prohibited.
- The Association is empowered to enforce these rules, including discontinuing water service upon violations.
- Moving in or out requires clearance from FPA to maintain security and compliance.
Proceedings Below
- After Cariday leased its building to two unrelated tenants, FPA denied access to the second tenant based on the violation of the "one single-family residential building per lot" rule.
- FPA threatened to disconnect water service as enforcement.
- Cariday filed for injunction to restrain FPA from disconnecting water or preventing tenant access.
- The trial court granted prelimina