Case Summary (G.R. No. 194024)
Factual and Procedural Antecedents
In 1996, Pacifico Lim executed the MDDR for the Phoenix Heights Condominium, which was subsequently filed with the Registry of Deeds. Distinction Properties was responsible for the development and marketing of the condominium units and later transferred the ownership of the condominium to the Phoenix Heights Condominium Corporation (PHCC), retaining certain units for administrative purposes. In 2008, the petitioners filed a complaint with the Housing and Land Use Regulatory Board (HLURB) against the respondent, claiming violations of its obligations and misleading advertising concerning the condominium’s amenities.
HLURB Decision
The HLURB found in favor of the petitioners, declaring the agreements regarding the conversion of certain units into common areas as invalid due to lack of approval from the necessary corporate majority. The HLURB ordered the respondent to restore certain facilities and to pay the petitioners damages and dues. The HLURB claimed jurisdiction over the dispute, characterizing it as being within the scope of P.D. No. 957, which governs real estate transactions.
Court of Appeals Decision
Distraught, the respondent appealed to the Court of Appeals (CA), asserting that the HLURB had no jurisdiction over the case and the petitioners lacked standing to sue as the PHCC was an indispensable party not joined in the complaint. The CA ruled in favor of the respondent, annulling the HLURB's decision on grounds that the HLURB lacked jurisdiction, and deeming the petitioners' claims as intra-corporate disputes, which should have been filed in a different forum.
Petitioners’ Arguments
The petitioners countered that the HLURB indeed had jurisdiction, asserting that their complaint arose from the contracts with the developer regarding their rights as condominium unit owners. They argued that the case involved claims for specific performance of contractual obligations and were thus cognizable under HLURB's jurisdiction as defined by P.D. No. 957.
Respondent’s Defense
The respondent contended the HLURB's ruling was erroneous and maintained that the core issues involved the corporate actions of PHCC, which made PHCC an indispensable party. They argued that the absence of PHCC justified the dismissal of the petitioners' claims.
Supreme Court Decision
The Supreme Court upheld the decision of the CA, affirming that the HLURB lacked jurisdiction over the subject matter of the complaint filed by the petitioners. The Court clarified that the nature of the claims involved constituted an intra-corporate controversy, which falls within the jurisdiction of the Regu
...continue readingCase Syllabus (G.R. No. 194024)
Overview of the Case
- The case is a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- It challenges the March 17, 2010 Decision and October 7, 2010 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 110013.
- The petitioners are Philip L. Go, Pacifico Q. Lim, and Andrew Q. Lim, while the respondent is Distinction Properties Development and Construction, Inc. (DPDCI).
Factual Background
- Petitioners are registered individual owners of condominium units in Phoenix Heights Condominium located in Pasig City, Metro Manila.
- DPDCI is a corporation engaged in real estate development, specifically the Phoenix Heights Condominium.
- Pacifico Lim, as president of DPDCI, executed a Master Deed and Declaration of Restrictions (MDDR) for the condominium in February 1996.
- DPDCI managed the marketing, sale of units, and distribution of promotional materials for the project.
- In 2000, DPDCI turned over ownership and possession of the condominium to Phoenix Heights Condominium Corporation (PHCC), retaining two commercial units.
- DPDCI was charged association dues for the commercial units despite their use by PHCC.
- In 1999, DPDCI’s application for alteration of the condominium's plan was denied due to obstruction concerns.
Legal Proceedings Initiated by Petitioners
- In August 2008, petitioners filed a complaint with the Housing and Land Use Regulatory Board (HLURB) against DPDCI for unsound business practices and MDDR violations.
- They alleged misrepresentation regarding facilities in promotional materials and DFDCI's failure to comply with the MDDR.
- DPDCI contended that the brochure was a draft and questioned the petitioners' standing to sue, cla