Makati Tuscany Condominium Corporation v. Multi-Realty Development Corporation

Summary

This case involved a dispute over ownership of 98 parking slots in Makati Tuscany condominium. Multi-Realty developed the project and executed a Master Deed that included these slots as common areas transferred to MATUSCO. However, Multi-Realty continued selling the slots and MATUSCO cooperated by issuing management certificates and even offering to buy remaining slots. When slot values increased dramatically in 1989, MATUSCO claimed ownership. The Supreme Court granted reformation of the instruments, finding that the parties' subsequent conduct proved their true intention was for Multi-Realty to retain ownership. The Court emphasized that reformation is allowed when written instruments fail to reflect true party intentions due to mistake, and that subsequent acts can prove original intent. This case demonstrates the principle that contracts should reflect actual party agreements, not just written terms.