Siasoco v. Narvaja
REITERATIONFacts
1. The Antecedents: David Siasoco was the registered owner of Lot Nos. 29 and 30, Block 2 of the Saint John Village, Sta. Rosa, Laguna. His heirs, the petitioners herein, allegedly sold these lots to respondent Januario Narvaja on August 20, 1984. Respondent Narvaja later filed a complaint for specific performance against petitioner Rodolfo A. Siasoco with the Housing and Land Use Regulation Board (HLURB) to compel the execution of a deed of absolute sale and the delivery of the corresponding transfer certificates of title. 2. Procedural History: The HLURB Arbiter initially ordered the petitioners to accept the balance of the purchase price and to execute the deed of sale and deliver the titles. This decision was affirmed by the HLURB Board of Commissioners after the petitioners' appeal was dismissed for failure to prosecute. Subsequently, a deed of absolute sale was executed by the HLURB Arbiter on behalf of petitioner Rodolfo A. Siasoco. However, the Registrar of Deeds refused to register the deed without the owner's duplicate certificates of title. When petitioner Rodolfo A. Siasoco refused to surrender these certificates, respondent Narvaja filed a petition with the Regional Trial Court (RTC) to compel their surrender. The RTC denied the petitioners' motions to dismiss and to suspend proceedings. The Court of Appeals affirmed the RTC's denial. 3. The Petition: The petitioners, as heirs of David Siasoco, are seeking a review on certiorari of the Court of Appeals' decision. They contend that the appellate court erred in not setting aside the RTC's orders denying their motions to dismiss and to suspend proceedings. Specifically, they argue that the HLURB has original and exclusive jurisdiction over the case, not the trial court, and that a pending case involving the same issues and parties existed in the HLURB. They assert that the RTC lacked jurisdiction to entertain the petition to compel the surrender of the owner's duplicate certificates of title.
Issue(s)
Whether the Regional Trial Court has jurisdiction over a petition to compel the surrender of owner's duplicate certificates of title when the underlying dispute involves a complaint for specific performance that falls under the exclusive jurisdiction of the HLURB. Whether the Court of Appeals erred in affirming the denial of the petitioners' motion to dismiss and motion to suspend proceedings, considering the HLURB's primary jurisdiction over the specific performance case.
Ruling
The decision of the Court of Appeals is REVERSED, and the petition filed by respondent Januario N. Narvaja is DISMISSED.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the Housing and Land Use Regulatory Board (HLURB) has exclusive jurisdiction over cases of specific performance filed against subdivision developers to compel the execution of deeds of absolute sale and the delivery of certificates of title. This jurisdiction is granted by Executive Order No. 648, Section 8(11), as amended by Executive Order No. 90. The Court cited its ruling in United Housing Corporation v. Dayrit, which established that the HLURB, not the trial court, has jurisdiction over such complaints. Therefore, the petition to require the surrender of the owner's duplicate certificates of title, which is a necessary step to effect the transfer of ownership ordered in the specific performance case, should have been filed before the HLURB. The RTC should have dismissed the action for lack of jurisdiction. The Court distinguished the present case from United Housing Corporation v. Dayrit by noting that the circumstances necessitating resort to the courts due to the seller's refusal and the regulatory body's inaction were not present here. The respondent had already secured a favorable decision from the HLURB and should have pursued the ancillary relief before the same body. Therefore, the Court of Appeals erred in affirming the denial of the petitioners' motions, as the HLURB had primary jurisdiction.
Main Doctrine
The Housing and Land Use Regulatory Board (HLURB) has exclusive jurisdiction over cases of specific performance filed against subdivision developers to compel the execution of deeds of absolute sale and the delivery of certificates of title. Consequently, a petition to require the surrender of owner's duplicate certificates of title, arising from such a case, should be filed before the HLURB, not the Regional Trial Court.