GR 220042; (September, 2018) (Digest)
G.R. No. 220042. September 05, 2018
CASA MILAN HOMEOWNERS ASSOCIATION, INC., PETITIONER, VS. THE ROMAN CATHOLIC ARCHBISHOP OF MANILA AND REGISTER OF DEEDS OF QUEZON CITY, RESPONDENTS.
FACTS
B.C. Regalado & Co., Inc. owned the Casa Milan Subdivision, with Lot 34 designated as an open space or park. In 1995, The Roman Catholic Archbishop of Manila (RCAM) began constructing a church on a portion of this lot. The application for the lot’s segregation and conversion, supported by a letter from residents, was processed through the Housing and Land Use Regulatory Board and later approved by the Quezon City Council in 2007. In 2002, Regalado executed a Deed of Donation over a 4,000-square meter portion of Lot 34 in favor of RCAM. The Casa Milan Homeowners Association, incorporated only in 1999, filed a complaint in 2009. It alleged the donation was invalid for lack of its written consent and that RCAM built the church in bad faith. It sought to cancel the titles derived from the donation and to restore the lot as open space.
The Roman Catholic Archbishop of Manila moved to dismiss the complaint for failure to state a cause of action, among other grounds. The Regional Trial Court granted the motion, a ruling affirmed by the Court of Appeals. The appellate court held the complaint failed to allege that the Association ever acquired a legal right over the open space that would obligate the defendants to secure its consent.
ISSUE
Whether the Court of Appeals committed reversible error in affirming the dismissal of the complaint for failure to state a cause of action.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic centers on the elements of a cause of action and the petitioner’s failure to establish a legal right. A cause of action exists if the complaint alleges a legal right of the plaintiff, a correlative obligation of the defendant, and an act or omission by the defendant in violation of that right. The Court found the complaint fatally deficient.
The petitioner’s claim rested on the requirement under Presidential Decree No. 957 that the conversion of subdivision open spaces requires the written consent of the homeowners association. However, the complaint itself revealed that the Association was incorporated in 1999, while the application for segregation and the supporting letter from residents occurred in 1995. Critically, the complaint did not allege that the Association had acquired ownership or any other vested legal right over the subject open space at the time of the donation or the construction. The lot remained registered under the name of the developer, Regalado. Without a pleaded legal right vested in the Association, there could be no correlative duty on the part of RCAM or the others to secure its consent. The alleged violation of a statutory procedure, absent a showing of a consequent infringement of a vested right belonging to the plaintiff, is insufficient to constitute a cause of action. The dismissal for failure to state a cause of action was therefore proper, as the defect was apparent from the four corners of the petition itself.