United Housing Corporation v. Dayrit
REITERATIONFacts
The Antecedents: Jose M. Tapia, Jr. purchased Lot 19, Block 28 from United Housing Corporation (UHC) under a Contract to Sell. Tapia fully paid the purchase price, but UHC failed to execute the Absolute Deed of Sale or transfer the title despite demands. Procedural History: Tapia filed a complaint before the Human Settlements Regulatory Commission (HSRC). A compromise agreement was reached, wherein UHC committed to deliver the title within two months. A judgment upon this compromise was rendered. UHC failed to comply. Tapia moved for execution, but UHC opposed. The HSRC forwarded the records for violation of P.D. 957, leading to a criminal information against UHC's president. The Petition: Spouses Tapia filed a new civil case for specific performance with damages before the Regional Trial Court (RTC) of Manila. UHC moved to dismiss, arguing the RTC lacked jurisdiction due to P.D. 1344 and E.O. 648, which vested exclusive jurisdiction in the HSRC. The RTC denied the motion to dismiss. UHC filed a petition for certiorari and prohibition with the Supreme Court.
Issue(s)
Whether the Regional Trial Court has jurisdiction over a complaint for specific performance of a contractual and statutory obligation filed by a subdivision lot buyer against the owner/developer, considering the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB) and the effect of a prior compromise agreement and judgment rendered by the Human Settlements Regulatory Commission (HSRC). Whether a new complaint for specific performance is tenable when a motion for execution of a prior judgment upon compromise agreement was filed but not acted upon by the HSRC, and what the proper recourse should have been.
Ruling
The petition is granted. The assailed Order of the RTC denying the motion to dismiss is annulled and set aside. Civil Case No. 37432 of the RTC is ordered dismissed. However, United Housing Corporation is ordered to deliver the title to Lot 19, Block 28 to Spouses Tapia within thirty (30) days from the finality of the decision.
Ratio Decidendi
On the jurisdiction of the RTC over specific performance cases involving subdivision lot buyers: The Supreme Court held that jurisdiction over cases for specific performance of contractual and statutory obligations filed by buyers of subdivision lots or condominium units against the owner or developer is vested exclusively in the Housing and Land Use Regulatory Board (HLURB), formerly the HSRC. This is explicitly provided for in Section 1 of P.D. 1344 and reinforced by Section 8 of E.O. 648. The Court reiterated that the HLURB has exclusive jurisdiction to regulate the real estate trade and business in accordance with P.D. No. 957. Therefore, the reliance of the private respondents on the Judiciary Reorganization Act of 1980 was untenable as it pertains to cases not within the exclusive jurisdiction of any other body. On the tenability of a new complaint for specific performance and the proper recourse: The Court found that the private respondents' resort to the RTC was prompted by the petitioner's failure to honor its commitment under the compromise agreement and the HSRC's failure to act on the motion for execution. However, the Court emphasized that a judgment upon a compromise agreement has the force of res judicata and is immediately executory. Upon failure of the HSRC to act on the motion for execution, the private respondents should have instituted mandamus proceedings to compel the HSRC to perform its ministerial duty. Filing a new complaint for specific performance before the RTC was therefore not the proper recourse. Despite this, the Court, in the interest of justice and to avoid perpetuating an iniquitous situation, ordered the petitioner to perform its obligation under the compromise agreement, considering the petitioner's failure to come to court with clean hands.
Main Doctrine
Cases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots or condominium units against the owner or developer fall under the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB), not the Regional Trial Court. A judgment upon a compromise agreement has the force of res judicata and is immediately executory.