G.R. No. 256648 , February 24, 2025
PETER RICO F. RODRIGUEZ, PETITIONER, vs. GREGORIO PASTORFIDE, RAMONA MATIBAG, CECIL L. MONTEBLANCO, AND ROLAND AGUSTIN ANGELES, IN THEIR PURPORTED CAPACITIES AS MEMBERS OF THE BOARD OF DIRECTORS OF MEDICAL PLAZA MAKATI CONDOMINIUM CORPORATION, RESPONDENTS.

FACTS

On October 16, 2018, Medical Plaza Makati Condominium Corporation (MPMCC) held its 20th Annual General Membership Meeting, which included the election of its Board of Directors. Respondents Gregorio Pastorfide, Ramona Matibag, Cecil L. Monteblanco, and Roland Agustin Angeles were included in the official list of seven candidates. Objections were raised regarding their qualifications because MPMCC’s By-Laws require that directors be members of the corporation, and membership is limited to registered owners of condominium units. It was confirmed that the respondents were not registered unit owners themselves but were authorized representatives of corporate unit owners (Pastorfide Land Corporation and Maxicare Health Corporation), which were members in good standing. Despite the objections, and because there were exactly seven candidates for seven seats, the Election Committee declared all candidates, including the respondents, elected.
Petitioner Peter Rico F. Rodriguez, a unit owner and MPMCC member, filed a Complaint for Election Contest and Damages before the Regional Trial Court (RTC). Respondents filed motions for extension of time to file a responsive pleading. Rodriguez moved to declare them in default, arguing such motions were prohibited under the Interim Rules for Intra-Corporate Controversies. The RTC initially granted extensions but later granted Rodriguez’s motion, declared respondents in default, and set aside their subsequently filed Answer. The RTC then rendered a Decision declaring the election of the respondents null and void, citing the By-Laws requirement and the case of Lim v. Moldex Land, Inc., which held that a corporate representative, while entitled to exercise membership rights, is not automatically qualified to be elected as a director if not a member in their own right.
Respondents filed a Petition for Certiorari with the Court of Appeals (CA) challenging the default orders. After the CA refused to issue injunctive relief, the RTC proceeded to decide the main case. Respondents then filed a Petition for Review with the CA assailing the RTC’s decision on the merits. The CA consolidated the cases. It dismissed the certiorari petition, finding the RTC acquired jurisdiction over respondents due to their voluntary appearance via the motions for extension. However, the CA granted the Petition for Review, reversed the RTC’s decision, and dismissed Rodriguez’s Complaint. The CA distinguished Lim v. Moldex Land, Inc., ruling it pertained to proxies, not designated authorized representatives. Rodriguez’s motion for reconsideration was denied.

ISSUE

Did the Court of Appeals err in ultimately dismissing Rodriguez’s Complaint for election contest?

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the CA’s Decision and Resolution.
While the issue may have been mooted by subsequent board elections, the Court exercised its power to resolve it as the case was capable of repetition yet evading review. On the merits, the Court held that a duly authorized representative of a corporate member of a condominium corporation is qualified to be elected as a member of its Board of Directors. The Court agreed with the CA’s distinction of Lim v. Moldex Land, Inc., noting that the respondents were not mere proxies but designated representatives of the corporate members. The corporate members themselves, being the registered unit owners, are the primary members of MPMCC. Their authorized representatives, by legal fiction, are considered members for the purpose of exercising corporate rights and obligations, including the right to be elected to the Board. To hold otherwise would unjustly deprive corporate members of their fundamental right to representation in the condominium corporation’s governance through their chosen agents. Therefore, the respondents were qualified, and the election was valid. The Petition was denied.