Manzanal v. Ilusorio (Case Digest)

Manzanal v. Ilusorio
G.R. No. 189311
December 6, 2010

DENNIS R. MANZANAL and BAGUIO COUNTRY CLUB CORPORATION, Petitioners
vs.
RAMON K. ILUSORIO, Respondent

Facts:
On July 7, 1994, a penthouse at the Baguio Country Club (BCCC) building was assigned by Felix Adolfo Lopez, Jr., with the conformity of BCCC, to Ramon Ilusorio. Ilusorio had lived there for years, but conflict within his family arose in 1998. Suddenly, he was barred from using the unit and was almost expelled as member of the club. Ilusorio sent a letter to BCCC to request for his current statement of account. BCCC replied and charged him with Php102,076.74, which he paid under protest.

Then he requested a breakdown of the amount, which BCCC, through Dennis Manzanal, complied with. In the answer, the breakdown amounted to Php2,928,223.26. Because this was much bigger than what Ilusorio paid, BCCC demanded that he pay the unpaid charges. Out of the more than 2.9 million breakdown, 2.4 million was billed for Ilusorio’s sponsorship of guests from April 1995 to July 1999. In Ilusorio’s reply to Manzanal’s letter of demand, he did not contradict the fact that his work partners and employees used his unit, admitting that he welched on his undertaking in the contract that only family members are allowed free usage. Ilusorio, however, said that he should not be charged for the use of the unit as he is entiled to its use and enjoyment being the owner thereof.

Because of the constant demand letters, Ilusorio took the matter to the Regional Trial Court. He felt that the demand letters were a form of harassment from his family, so he filed a complaint for damages. Instead of answering, Manzanal filed a motion to dismiss the complaint for failure to state a cause of action, which the trial court granted. Manzanal explained that the act of sending a demand letter does not constitute a cause of action against the obligee or creditor. However, upon appeal, the Court of Appeals reversed the RTC’s decision.

Issues:
Was the complaint for damages filed by Ramon Ilusorio against petitioner Dennis Manzanal and Baguio City Country Club Corporation state a cause of action?
Can BCCC collect the unpaid balance from Ilusorio?

Ruling:
No. A cause of action is the act or omission by which a party violates the right of another, entitling the injured party to relief. Its existence is determined from the allegations in the complaint. To sustain Ilusorio’s assertions that his complaint states a cause of action would be to rule that the act of sending a demand letter by itself constitutes a cause of action. The Court found that the demand letters did not deviate from the standard practice of pursuing the satisfaction of a club member’s obligations.

Yes. The Supreme Court cited Cebu Country Club, Inc., v. Elizagaque, which also cites Article 19 in relation with Article 21 of the Civil Code, which provide

Article 19. Every person must, in the exercise of his rights and in the performance of his duties, act with justice, give everyone his due, and observe honesty and good faith.

Article 21. Any person who wilfully causes loss or injury to another in manner that is contrary to morals, good customs or public policy shall compensate the latter for the damage.

As an exclusive organization that derives life from membership fees and charges, BCCC is expected to enforce claims from members in default of their contractual obligations.

When a right is exercised in a manner which does not conform with the norms enshrined in Article 19 of the Civil Code and results in damages to another, a legal wrong is thereby committed for which the wrongdoer must be held responsible. There is a need to connect Article 19 with Article 21 because the former does not provide a remedy for its violation.