Padcom Condominium Corporation vs. Ortigas Center Association, Inc.

Padcom Condominium Corporation vs. Ortigas Center Association, Inc.

G.R. No. 146807. May 9, 2002.

Facts:  
            Petitioner Padcom Condominium Corporation (PADCOM) owns and manages the Padilla Office Condominium Building (PADCOM BUILDING). The land on which the building stands was originally acquired from the Ortigas & Company, Limited Partnership, by Tierra Development Corporation (TDC) under a Deed of Sale with a condition that the transferee and its successor-in-interest must become members of an association for realty owners and long-term lessees in the area later known as the Ortigas Center. Subsequently, the said lot, together with the improvements thereon, was conveyed by TDC in favor of PADCOM in a Deed of Transfer.

Thereafter, respondent Ortigas Center Association, Inc. (ASSOCIATION) was organized to advance the interests and promote the general welfare of the real estate owners and long-term lessees of the lots in the Ortigas Center and sought the collection of membership dues from PADCOM. In view of PADCOM'S failure and refusal to pay its arrears in monthly dues, the Association filed a complaint for collection of sum of money before the trial court, but the same was dismissed. On appeal, the Court of Appeals reversed and set aside the trial court's dismissal. Hence, this petition.

Issue:
            Whether or not PADCOM is unjustly enriched by the improvements made by the Association, thus requiring the former to pay dues to the latter.

Held:
            Yes. The Supreme Court held that as resident and lot owner in the Ortigas area, PADCOM was definitely benefited by the Association's acts and activities to promote the interests and welfare of those who acquire property therein or benefit from the acts or activities of the Association.

Generally, it may be said that a quasi-contract is based on the presumed will or intent of the obligor dictated by equity and by the principles of absolute justice. Examples of these principles are: (1) it is presumed that a person agrees to that which will benefit him; (2) nobody wants to enrich himself unjustly at the expense of another; or (3) one must do unto others what he would want others to do unto him under the same circumstances.

Finally, PADCOM's argument that the collection of monthly dues has no basis since there was no board resolution defining how much fees are to be imposed deserves scant consideration. Suffice it is to say that PADCOM never protested upon receipt of the earlier demands for payment of membership dues. In fact, by proposing a scheme to pay its obligation, PADCOM cannot belatedly question the Association's authority to assess and collect the fees in accordance with the total land area owned or occupied by the members, which finds support in a resolution dated 6 November 1982 of the Association's incorporating directors and Section 2 of its By-laws.

Philippine National Bank vs. Purificacion Vda. De Villarin, et al.

Philippine National Bank vs. Purificacion Vda. De Villarin, et al.

[G.R. No. L-41036. September 5, 1975.

Facts:

The Philippine National Bank obtained in its favor a judgment which became final and executory on August 11, 1956. the judgment debtor died in 1961, and when the Bank learned of his death, it filed, on July 13, 1965, a petition for issuance of letter of administrative of the intestate estate of the deceased judgment debtor. Thereafter, or on March 17, 1966, the Bank filed a claim against the estate based on the judgment rendered in its favor. The Administratrix opposed the claim on the ground that the decision upon which the claim is based is already unenforceable pursuant to Article 1144(3) of the Civil Code which limits to ten years the prescriptive period within which an action to receive a judgment may be filed.

The Bank countered that its claim has not yet prescribed nor barred by the statute of limitations for although more ten years have already elapsed counted from the time judgment became final and executory, the prescriptive period was interrupted by the partial payment made by the judgment debtor after judgment became executory, indicating his acknowledgment of the existence of the debt.

On September 18, 1967, Porfirio Villarin, Jr. assisted by his mother, Purificacion Vda. de Villarin, likewise filed an opposition to the claim of the petitioner-claimant contending that said claim has been barred by the Statute of Limitations; that the money judgment relied upon by claimant Bank could have been enforced by an independent civil action for revival of judgment under Section 6, Rule 39 of the Rules of Court; and that the failure of the claimant Bank to institute such action for revival of judgment within the ten-year period from the time the judgment became final and executory on August 11, 1965 has watered down its claim to a mere natural obligation which does not grant a right of action to enforce its performance.

Issue:
            Whether or not the claim of the Bank has prescribed, making its claim to a mere natural obligation.

Held:
            No. The Supreme Court held that Under Section 6, Rule 39 of the Rules of Court "a judgment may be executed on motion within five (5) years from the date of its entry or from the date it becomes final and executory. After the lapse of such time, and before it is barred by the statute of limitations, a judgment may be enforced by action." Appellant Bank contends that its claim has not yet prescribed because its right to file the action to revive the aforesaid money judgment was still subsisting when the judgment debtor Porfirio Villarin died on January 18, 1961 and that its right to file an action to revive said money judgment was, after the death of Porfirio Villarin, converted into a claim enforceable only in the settlement of the intestate estate proceedings of the deceased. As such, it maintains that the applicable period of prescription is not the 10-year period for filing an action to revive a judgment but the period of prescription for the filing of creditor's claim against the judgment debtor's estate under Section 2, Rule 86 of the Rules of Court.

The records show that on July 13, 1965, the appellant Bank filed a petition for the issuance of letters of administration in the settlement of the intestate estate of Porfirio Villarin and on September 24, 1965, the letters of administration was issued in favor of the widow of Porfirio Villarin, Gregoria Vda. de Villarin. If the money judgment obtained by appellant Bank against Porfirio Villarin became final and executory on August 11, 1955, it has up to August 11, 1965 to file an action to revive the judgment. However, appellant Bank did not actually file an action to revive the money judgment but a claim against the estate of the deceased on March 9, 1966.

Therefore, the claims of the appellant Bank cannot be considered as a natural obligation.