G.R. No.

71169 December 22, 1988

Sangalang v. IAC

MAIN TOPIC – Contracts Clause

I. 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.

II. ISSUE

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

III. HELD

No. he court held that here 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 fence along Jupiter St. 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.

IV. DISPOSITIVE PORTION

WHEREFORE, premises considered, these petitions are DENIED No pronouncement as to costs.

IT IS SO ORDERED.

V. DOCTRINE/LAW

Non-impairment of contracts is constitutionally guaranteed but the rule is not absolute, since it has to be reconciled
with the legitimate exercise of police power.

Ponente: Sarmiento, J.

Digest Maker: Balina, Namiel Maverick