Tejada v. Homestead Property Corporation
REITERATIONFacts
The Antecedents: Private respondent Taclin V. Bañez offered to sell a 200 square meter lot owned by respondent corporation to petitioner Enriqueto F. Tejada for P230,000.00. Petitioner paid a reservation fee of P20,000.00, with the understanding that it would be part of the consideration if a sale was finalized, or returned if no agreement was reached. The tentative agreement stipulated a P1,150.00 per square meter price, a 24% downpayment of P55,200.00, and the balance payable monthly within one to two years. However, respondent corporation unilaterally altered the terms by increasing the proposed amortization payments. Petitioner refused to proceed with the purchase and demanded the return of the P20,000.00 reservation fee, which respondents refused. Procedural History: Petitioner filed a complaint for collection of a sum of money with damages against respondents with the Regional Trial Court (RTC) of Pasig. Respondents moved to dismiss, asserting that jurisdiction lies with the Human Settlements Regulatory Commission (HSRC). The RTC denied the motion, as well as the motion for reconsideration. Respondents elevated the matter to the Court of Appeals via a petition for certiorari, alleging grave abuse of discretion by the RTC. The Court of Appeals ruled that the HSRC (now the Housing and Land Use Regulatory Board [HLRB]) had jurisdiction over the case. The Petition: Petitioner argues that since no perfected contract of sale existed, the claim for the refund of the reservation fee falls within the jurisdiction of the regular courts, not the HSRC/HLRB.
Issue(s)
Whether the Regional Trial Court has jurisdiction over an action for the refund of a reservation fee for a real property purchase. Whether the Human Settlements Regulatory Commission (HSRC), now the Housing and Land Use Regulatory Board (HLRB), has exclusive jurisdiction over claims involving refund filed by subdivision lot or condominium unit buyers against project owners, developers, dealers, brokers, or salesmen.
Ruling
The petition is dismissed for lack of merit. The Housing and Land Use Regulatory Board (HLRB) has exclusive jurisdiction over the case.
Ratio Decidendi
On Whether the Regional Trial Court has jurisdiction over an action for the refund of a reservation fee for a real property purchase: The Court held that the jurisdiction over the controverted case lies with the Human Settlements Regulatory Commission (HSRC), now the Housing and Land Use Regulatory Board (HLRB). This is based on Section 1 of Presidential Decree No. 1344, which grants the National Housing Authority (NHA), and subsequently the HSRC/HLRB, exclusive jurisdiction to hear and decide claims involving refund filed by subdivision lot or condominium unit buyers against project owners, developers, dealers, brokers, or salesmen. The law does not distinguish between a perfected sale and one that has yet to be perfected, and the term "buyer" should be understood to include anyone who offers to buy. The Court emphasized that when an administrative agency is conferred quasi-judicial functions, all controversies relating to the subject matter pertaining to its specialization are deemed included within its jurisdiction, and split jurisdiction is not favored. Since the action for refund of the reservation fee arose from a proposed purchase of a subdivision lot, the HLRB has exclusive jurisdiction over the case. On Whether the Human Settlements Regulatory Commission (HSRC), now the Housing and Land Use Regulatory Board (HLRB), has exclusive jurisdiction over claims involving refund filed by subdivision lot or condominium unit buyers against project owners, developers, dealers, brokers, or salesmen: The Court agreed with the respondent appellate court's observation that the HLRB has exclusive jurisdiction over claims involving refund filed against project owners, developers, and dealers, among others, and that the elimination of the requirement for the claim to be made by a "buyer" under Executive Order No. 90 further solidifies this exclusive jurisdiction.
Main Doctrine
The Housing and Land Use Regulatory Board (HLRB), by virtue of Presidential Decree No. 1344 and subsequent executive orders, has exclusive jurisdiction over claims involving refund filed by subdivision lot or condominium unit buyers against project owners, developers, dealers, brokers, or salesmen, regardless of whether the sale has been perfected or not. Split jurisdiction is not favored, and all controversies relating to the subject matter pertaining to the HLRB's specialization are deemed included within its jurisdiction.