G.R. No. 146807. May 09, 2002 (Case Brief / Digest)

### Title:
**Padcom Condominium Corporation vs. Ortigas Center Association, Inc.: A Case on Compulsory Membership and Liens**

### Facts:
This case involves Padcom Condominium Corporation (PADCOM), owner and manager of the Padilla Office Condominium Building in Pasig City, and Ortigas Center Association, Inc. (the Association), an organization representing real estate owners and long-term lessees in Ortigas Center. The land on which PADCOM’s building stands was initially bought from Ortigas & Company, Limited Partnership (OCLP) by Tierra Development Corporation (TDC) in 1974, with a stipulation for the buyer to become a member of an association, subsequently leading to the creation of the Association in 1982.

PADCOM became the successor-in-interest after purchasing the land from TDC in 1975. The Association later demanded membership dues from PADCOM, claiming dues in arrears. Despite exchanges that included demands for payment, PADCOM argued against compulsory membership and related dues. The dispute led the Association to file a complaint for the collection of the alleged dues, which was initially dismissed by the Regional Trial Court of Pasig City but was overturned by the Court of Appeals. PADCOM then escalated the matter to the Supreme Court.

### Issues:
1. Whether PADCOM can be compelled to join the Association and pay dues based on a clause indicating automatic membership upon land purchase within the Ortigas Center.
2. Whether PADCOM’s right to freedom of association is violated by enforced membership in the Association.
3. Whether the dues and penalties assessed by the Association were validly imposed and enforceable against PADCOM.

### Court’s Decision:
The Supreme Court denied PADCOM’s petition, upholding the decision of the Court of Appeals. The High Court reasoned that:
1. PADCOM was bound by the covenant of automatic membership as this stipulation was included in the Deed of Sale and evidenced on the Transfer Certificate of Title. The Torrens system, under Presidential Decree No. 1529, supports that any encumbrance annotated on the title binds the land’s holder, hence PADCOM, as a successor-in-interest, is obligated to comply.
2. The automatic membership clause and PADCOM’s subsequent actions did not violate its right to freedom of association, as PADCOM had the choice not to buy the land knowing the stipulation.
3. PADCOM is estopped from denying membership as it had acknowledged and sought extensions for payment of dues, indicating an acceptance of its member status and the obligations that come with it.

### Doctrine:
This case reaffirms the binding nature of annotations on the Transfer Certificate of Title under the Torrens system. It also establishes that a stipulation for automatic membership in an association, annotated as an encumbrance on the title, is enforceable against successors-in-interest. Furthermore, it underscores the application of estoppel in cases where a party’s conduct implies acceptance of obligations.

### Class Notes:
1. **Torrens System of Registration:** Claims and liens annotated on the transfer certificate of title bind the landowner and successors-in-interest.
2. **Freedom of Association:** The right to freedom of association is not violated by conditions willingly accepted by undergoing a contractual transaction.
3. **Estoppel:** A party may be barred from denying obligations if their previous conduct has indicated acknowledgment or acceptance of such.
4. **Quasi-Contracts:** Even without a formal contract, obligations may arise from the principle of unjust enrichment, requiring parties to act in equity.

### Historical Background:
This case situates within the broader context of property ownership, association membership, and the rights and obligations these entail. The automatic membership clause in real estate within planned developments like the Ortigas Center reflects the intertwining of property rights with communal responsibilities, showcasing how property law interacts with civil rights such as freedom of association.


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