C.T. Torres Enterprises, Inc. v. Hibionada
REITERATIONFacts
The Antecedents: Petitioner C.T. Torres Enterprises, Inc., as agent of Pleasantville Development Corporation, sold a subdivision lot on installment to Efren Diongon. After Diongon completed payments, he demanded the delivery of the certificate of title, which was not complied with by either petitioner or Pleasantville. Procedural History: Diongon filed a complaint for specific performance and damages against C.T. Torres Enterprises, Inc. and Pleasantville Development Corporation in the Regional Trial Court (RTC) of Negros Occidental, docketed as Civil Case No. 3514. The defendants filed their respective answers. After pre-trial and submission of trial briefs, C.T. Torres Enterprises, Inc. filed a motion to dismiss, asserting that the Housing and Land Use Regulatory Board (HLURB) had exclusive jurisdiction over the case by virtue of Executive Order No. 90. The RTC denied the motion to dismiss, holding that the complaint for specific performance with damages was a justiciable issue under the New Civil Code, cognizable by regular courts under Batas Pambansa Blg. 129. The Petition: C.T. Torres Enterprises, Inc. filed a petition for certiorari with the Supreme Court, questioning the RTC's order denying its motion to dismiss.
Issue(s)
Whether the Regional Trial Court has jurisdiction over a complaint for specific performance and damages filed by a subdivision lot buyer against the developer. Whether a motion for reconsideration is a mandatory prerequisite before filing a petition for certiorari when the issue raised is one of jurisdiction.
Ruling
The petition is GRANTED. The questioned Order of September 17, 1987, is SET ASIDE and Civil Case No. 3514 in the Regional Trial Court of Negros Occidental is hereby DISMISSED, without prejudice to the filing of the proper complaint with the Housing and Land Use Regulatory Board if so desired.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the RTC erred in not considering the express provisions of P.D. No. 1344 and related decrees. Presidential Decree No. 957 vests the National Housing Authority (now HLURB) with exclusive authority to regulate the real estate trade. Specifically, Section 1(c) of P.D. No. 1344 grants the HLURB exclusive jurisdiction to hear and decide cases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots or condominium units against the owner, developer, dealer, broker, or salesman. The complaint filed by Diongon for specific performance with damages, seeking the delivery of the certificate of title for a subdivision lot, clearly falls within this exclusive jurisdiction. The Court reiterated that administrative agencies, by legislative authorization, can exercise quasi-judicial functions, including the adjudication of claims resoluble under the Civil Code, as a matter of expediency and to address the dockets of regular courts. The argument that only courts of justice can adjudicate claims under the Civil Code is outdated in light of the proliferation of administrative bodies with specialized expertise. On the procedural issue of premature filing: The Court ruled that a motion for reconsideration may be dispensed with when the issue raised is a pure question of law, as in the case of lack of jurisdiction. Therefore, the petition for certiorari was properly filed directly with the Supreme Court without the necessity of first filing a motion for reconsideration with the RTC. The issue of jurisdiction could be raised immediately to prevent further proceedings in a court that lacks the authority to hear the case.
Main Doctrine
Cases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots or condominium units against the owner, developer, dealer, broker or salesman fall under the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB), not the regular courts, even if the claim involves damages and is resoluble under the Civil Code.