GR 146807; (May, 2002) (Digest)
G.R. No. 146807. May 9, 2002. PADCOM CONDOMINIUM CORPORATION, petitioner, vs. ORTIGAS CENTER ASSOCIATION, INC., respondent.
FACTS
Petitioner Padcom Condominium Corporation (PADCOM) owns a building on a lot in Ortigas Center originally acquired from Ortigas & Company by Tierra Development Corporation (TDC). The 1974 Deed of Sale to TDC contained a condition requiring the transferee and its successors-in-interest to become members of an association for realty owners in the area. This condition was annotated on the title. TDC conveyed the property to PADCOM in 1975. Respondent Ortigas Center Association, Inc. (Association) was organized in 1982. It demanded payment from PADCOM of accumulated membership dues, interests, and penalties totaling P639,961.47 from 1983 to 1993. PADCOM refused payment, denying it was a member.
The Association filed a collection case. The Regional Trial Court dismissed the complaint, agreeing with PADCOM that membership was not automatic but required application and acceptance. The Court of Appeals reversed, ruling PADCOM was automatically a member by virtue of the annotated condition and its conduct, and ordered payment of the dues.
ISSUE
Whether PADCOM can be compelled to join the Association and pay membership dues based on the “automatic membership” clause annotated on the title.
RULING
Yes. The Supreme Court affirmed the Court of Appeals. The condition in the original Deed of Sale, binding on the buyer and its successors, was a real obligation that ran with the land upon its annotation on the certificate of title. This annotation constituted constructive notice to the whole world, including PADCOM as a subsequent purchaser. Therefore, PADCOM voluntarily assumed the obligation to become a member of the Association upon its organization.
PADCOM’s conduct also estopped it from denying membership. It repeatedly acknowledged the Association’s demands by requesting extensions and even proposing a settlement scheme for its arrears. Furthermore, the equitable principle against unjust enrichment under quasi-contracts applies. PADCOM, as a property owner in Ortigas Center, benefited from the Association’s activities aimed at promoting the welfare and interests of lot owners in the area. It cannot now evade the corresponding obligation to contribute. The claim that the dues lacked a board resolution basis was belied by PADCOM’s own prior actions acknowledging the debt.