Case Summary (G.R. No. L-24693)
Applicable Law
Relevant to the case is Article 1149 of the Civil Code, which addresses the prescription of actions and establishes a five-year period for certain claims. Additionally, the conditions set forth in the club's bylaws regarding the registration of membership assignments are pivotal to the case's outcome.
Drama of Events and Initiation of Legal Action
On April 26, 1955, Lee instituted a case in the Court of First Instance of Manila, asserting that the refusal of Wack Wack Golf & Country Club to acknowledge his ownership and issue a new certificate was unlawful. The defendant responded on June 6, 1955, with a motion to dismiss, citing the lapse of time since the assignment in 1944 as a bar to the action based on the five-year prescription period established in the Civil Code.
Court Ruling on Dismissal
The Court of First Instance dismissed the complaint on July 30, 1955, asserting that the plaintiff's right of action had expired. Subsequent motions for reconsideration filed by the plaintiff on August 27 and September 13, 1955, were denied, compelling the plaintiff to appeal the dismissal.
Examination of Rights and Responsibilities
The court assessed whether the plaintiff was obligated by the bylaws of the defendant club to register the assigned membership certificate within a specific timeframe. The defendant conceded that the right to register commenced upon the assignment; however, it contended that immediate action was warranted. The ruling clarified that the existence of a right is distinct from the duration of that right, emphasizing that no fixed period was mandated for the registration of the assignment.
Critical Analysis of Timeframes and Claims
The court raised pertinent questions regarding the timing of the registration efforts made by the plaintiff. The claim was based on the alleged refusal of the defendant to recognize the plaintiff's ownership, which purportedly occurred in February 1955. The complaint filed on April 26, 1955, either a few days or two months after the demand for registration was made, was examined in light of the absence of a prescription period specified by the defendant's b
...continue readingCase Syllabus (G.R. No. L-24693)
Case Overview
- This case involves a dispute between the plaintiff, Lee E. Won (alias Ramon Lee), and the defendant, Wack Wack Golf & Country Club, Inc., regarding the registration of a membership certificate.
- The case was decided by the Supreme Court of the Philippines on August 30, 1958, under G.R. No. L-10122.
Factual Background
- On December 2, 1942, the defendant, a non-stock corporation, issued Membership Certificate No. 201 to Iwao Teruyama.
- On April 22, 1944, Teruyama assigned this membership certificate to M. T. Reyes.
- Later in 1944, Reyes transferred and assigned the same certificate to the plaintiff, Lee E. Won.
- Following the post-war rehabilitation of the defendant, the plaintiff approached the defendant to register the assignment in his favor and to issue a new certificate, which the defendant refused to do.
Procedural History
- On April 26, 1955, the plaintiff filed an action in the Court of First Instance of Manila, claiming ownership of the membership certificate and seeking the issuance of a new certificate.
- The defendant filed a motion to dismiss the complaint on June 6, 1955, arguing that the plaintiff's right to action had accrued in 1944, and the complaint