E.G.V. Realty Development Corporation v. Court of Appeals

Summary

This case involved a dispute between condominium corporations and a unit owner over unpaid monthly dues versus claimed robbery damages. Unisphere International stopped paying P13,142.67 in condominium dues after two robberies in its unit totaling P12,295.00 in losses, claiming the condominium corporation failed to provide adequate security. The Court of Appeals allowed set-off between these amounts, but the Supreme Court reversed, holding that no proper legal compensation existed under Civil Code Articles 1278-1279. The SC distinguished between a liquidated 'debt' and a mere 'claim,' ruling that Unisphere's robbery losses were unproven claims that had not been formally adjudicated, thus preventing legal set-off. The case also involved significant procedural issues regarding appeal deadlines and the prohibition against second motions for reconsideration without leave. The decision clarifies the strict requirements for legal compensation and emphasizes procedural compliance in quasi-judicial appeals.