Case Summary (G.R. No. 154739)
Background and Initial Proceedings
The NHA received a complaint from Panotes, claiming that PROSECOR violated several provisions of P.D. No. 957, including the lack of open space in the subdivision. An ocular inspection verified this claim, leading the NHA to issue a Resolution on August 14, 1980, mandating PROSECOR to allocate Block 40 of the subdivision as open space. As PROSECOR did not appeal the NHA Resolution, it became final and executory.
Ownership Transfer and Subsequent Litigation
After the decision of the NHA, PROSECOR sold lots, including Block 40, to CTDC without informing them of the open space requirement imposed by the NHA. Bumatay, succeeding Panotes, sought to revive the NHA Resolution and named CTDC as a defendant. CTDC contested the revival, arguing that Bumatay lacked legal standing and there were pending litigations concerning Block 40.
HLURB Decision and Appellate Procedure
The HLURB ruled in favor of Bumatay on October 15, 1991, reviving the NHA Resolution and designating Block 40 as open space. CTDC’s subsequent appeals reached the Office of the President, which affirmed the HLURB decision. Following a procedural dismissal due to inadequate filings, CTDC eventually reinstated its petition, leading the Court of Appeals to reverse the Office of the President's decision on January 29, 2002, thus dismissing Bumatay's complaint.
Determining the Successor-in-Interest Issue
The core legal issue revolved around whether the NHA Resolution could be enforced against CTDC. The Supreme Court clarified that the NHA Resolution addressed the obligations of PROSECOR as the original developer and that CTDC merely purchased lots as an ordinary buyer, not as a successor-in-interest responsible for developer obligations. Since CTDC was not involved in the original judgment against PROSECOR, it could not be held accountable for the resulting obligations articulated in the NHA Resolution.
Court's Conclusion on Good Faith Purchase
The Court emphasized that CTDC had purchased the property in good faith and without notice of encumbrances. The absence of annotation of the NHA Resolution on the title of PROSECOR further supported CTDC's position as a good faith buyer. The
...continue readingCase Syllabus (G.R. No. 154739)
Case Background
- The case arises from a complaint filed by Rogelio (Roger) Panotes, then president of the Provident Village Homeowners Association, Inc., against Provident Securities Corporation (PROSECOR) in April 1979.
- The complaint, lodged with the National Housing Authority (NHA), was assigned NHA Case No. 4175 and accused PROSECOR of violating various sections of Presidential Decree No. 957.
- One significant allegation was PROSECOR's failure to provide an open space within the subdivision, a requirement under the law.
- An ocular inspection confirmed the absence of open space in the subdivision.
NHA Resolution and Subsequent Events
- The NHA issued a Resolution on August 14, 1980, directing PROSECOR to designate Block 40, measuring 22,916 square meters, as open space for the subdivision.
- PROSECOR did not appeal this resolution, leading it to become final and executory.
- When Panotes sought execution of this resolution, it was discovered that the case records were missing, resulting in a provisional dismissal of his motion.
- PROSECOR subsequently sold several lots, including Block 40, to City Townhouse Development Corporation (CTDC), which was unaware of the NHA's directive.
Change in Representation
- After Panotes, Araceli Bumatay succeeded him as president of the Provident Village Homeowners Association.
- On July 17, 1990, Bumatay filed a complaint with the Housing and Land Use Regulatory Board (HL