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Sangalang v. IAC

1) The Mayor of Makati directed a village association to open several streets to the public, including Jupiter St, after changes to zoning regulations. Homeowners opposed the opening of Jupiter St and filed lawsuits claiming breach of contract by the developer, Ayala Corporation, to maintain the residential status of the area. 2) The key issue is whether there was a contract between homeowners and Ayala Corporation that was violated by opening Jupiter St to public use. 3) The court found no contract existed, so nothing was violated. Even if a contract existed, it would have been overridden by legitimate zoning ordinances representing an exercise of police power, which were not shown to be capricious or unreasonable.

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93 views1 page

Sangalang v. IAC

1) The Mayor of Makati directed a village association to open several streets to the public, including Jupiter St, after changes to zoning regulations. Homeowners opposed the opening of Jupiter St and filed lawsuits claiming breach of contract by the developer, Ayala Corporation, to maintain the residential status of the area. 2) The key issue is whether there was a contract between homeowners and Ayala Corporation that was violated by opening Jupiter St to public use. 3) The court found no contract existed, so nothing was violated. Even if a contract existed, it would have been overridden by legitimate zoning ordinances representing an exercise of police power, which were not shown to be capricious or unreasonable.

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lancebryann
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Sangalang v. IAC (G.R. No. 71169.

December 22, 1988)

FACTS: The Mayor of Makati directed Bel-Air Village Association (BAVA) to opening of several streets to the general
public, after a series of developments in zoning regulations. All but Jupiter St. was voluntarily opened. The strong
opposition later gave way when the municipal officials force-opened the gates of said street for public use. The
area ceased to be purely residential. Action for damages was brought against Ayala Corporation and BAVA for
alleged breach of contract, to maintain the purely residential status of the area. Other similarly situated also filed
their respective cases. All were dismissed in the trial court. The Court of Appeals affirmed the said dismissals.

ISSUE: Whether or not there is a contract between homeowners and Ayala Corporation violated in opening the
Jupiter street for public use.

HELD: No. There was no contract to speak of in the case, hence nothing was violated. Petitioners cannot
successfully rely on the alleged promise by Ayala Corporation, to build a “[f]ence along Jupiter [street] with gate
for entrance and/or exit as evidence of Ayala’s alleged continuing obligation to maintain a wall between the
residential and commercial sections. Assuming there was a contract violated, it was still overtaken by the passage
of zoning ordinances which represent a legitimate exercise of police power. The petitioners have not shown why
Courts should hold otherwise other than for the supposed “non-impairment” guaranty of the Constitution, which is
secondary to the more compelling interests of general welfare. The Ordinance has not been shown to be
capricious or arbitrary or unreasonable to warrant the reversal of the judgments so appealed.

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