Sandoval v. Cañeba
REITERATIONFacts
The Antecedents: Private respondent filed a complaint against petitioner in the Regional Trial Court (RTC) of Manila for the collection of unpaid installments on a subdivision lot, based on a promissory note, plus interest. Petitioner allegedly suspended payments due to the developer's failure to develop the subdivision as agreed. Procedural History: The trial court declared petitioner in default and, after receiving evidence from the private respondent, rendered a decision ordering petitioner to pay the outstanding sum, interest, attorney's fees, and costs. Subsequently, the trial court issued a writ of execution to enforce the judgment. Petitioner filed a motion to vacate the judgment and dismiss the complaint, arguing the court lacked jurisdiction and its decision was void. He also filed a motion for reconsideration of the writ of execution. The trial court denied the motion to vacate, stating it was beyond its jurisdiction to do so, and reiterated the order for a writ of execution. The Petition: Petitioner filed a petition alleging that the respondent judge committed grave abuse of discretion and acted without jurisdiction in taking cognizance of the complaint, as exclusive and original jurisdiction over the subject matter is vested with the Housing and Land Use Regulatory Board (HLURB) under Presidential Decree No. 957. Petitioner also argued that the judge gravely abused his discretion in refusing to vacate the void judgment and in issuing a writ of execution.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over a collection case for unpaid installments on a subdivision lot. Whether the RTC committed grave abuse of discretion in rendering a judgment and issuing a writ of execution when it lacked jurisdiction over the subject matter.
Ruling
The petition is GRANTED. The questioned decision of the trial court dated January 29, 1988, is declared null and void for lack of jurisdiction. The trial court should have recalled and cancelled the writ of execution.
Ratio Decidendi
On the jurisdiction of the RTC over collection of unpaid installments for subdivision lots: The Court held that the Regional Trial Court (RTC) has no jurisdiction over the subject matter of the case. Presidential Decree No. 957 vests exclusive jurisdiction to hear and decide cases involving claims by subdivision lot buyers against project owners, developers, dealers, brokers, or salesmen, including claims for specific performance of contractual and statutory obligations, with the National Housing Authority (NHA), which was subsequently renamed the Housing and Land Use Regulatory Board (HLURB). The language of Section 1 of PD 957 clearly indicates that the NHA (now HLURB) has exclusive jurisdiction over such matters, leaving no room for doubt that the RTC cannot assume cognizance of these cases. The sum sought to be collected by the private respondent represented unpaid installments for a subdivision lot, which falls squarely within the exclusive jurisdiction of the HLURB. Therefore, the RTC acted without jurisdiction in taking cognizance of the complaint and rendering a decision. On the RTC's grave abuse of discretion in rendering a void judgment and issuing a writ of execution: The Court found that the respondent judge committed a grave abuse of discretion and acted without jurisdiction in refusing to vacate his judgment, which was rendered without jurisdiction. Since the trial court lacked jurisdiction over the subject matter, the decision it rendered is considered null and void ab initio, meaning it is as if no decision was rendered at all. Consequently, such a void judgment cannot become final and executory, nor can it be enforced by a writ of execution. When the trial court's attention was drawn to its lack of competence, it had a duty to vacate the judgment by declaring it null and void. Instead, the trial court reiterated the issuance of a writ of execution, which was an act performed without jurisdiction and in grave abuse of discretion. The proper course of action should have been to recall and cancel the writ of execution.
Main Doctrine
The Regional Trial Court (RTC) has no jurisdiction over cases involving the collection of unpaid installments for subdivision lots, as exclusive and original jurisdiction is vested with the Housing and Land Use Regulatory Board (HLURB) pursuant to Presidential Decree No. 957. A judgment rendered by an RTC in such a case is null and void ab initio.