Cole v. Court of Appeals
REITERATIONFacts
The Antecedents: The case originated from a complaint for non-delivery of title filed with the Housing and Land Use Regulatory Board (HLURB) Arbiter by several buyers against private respondent Julieta Agda and PNB. The HLURB Arbiter ordered Agda and PNB to deliver the title free from liens. PNB appealed to the HLURB Board of Commissioners, which affirmed the Arbiter's decision. The Office of the President also affirmed this decision. Agda, however, questioned the Arbiter's decision before the Court of Appeals (CA) via a petition for certiorari, which the CA dismissed on grounds of laches. Subsequently, Agda filed an action for rescission of contract against Lolita and Pete Cole in the Regional Trial Court (RTC). The CA dismissed this rescission case, ruling that Agda engaged in forum shopping and that the HLURB Board of Commissioners' decision was res judicata. Agda appealed this CA decision to the Supreme Court, which was dismissed for being filed out of time. Agda then filed a petition for annulment of judgment with the CA, seeking to annul the decisions of the HLURB Arbiter and the Office of the President. This led to a petition for mandamus with the Supreme Court (G.R. No. 137551) to compel the CA to resolve Agda's motion to dismiss the annulment petition. Meanwhile, Agda filed another petition for review with the Office of the President, questioning the 1995 decision of the Board of Commissioners. This prompted another petition with the Supreme Court (G.R. No. 138249) to dismiss this new petition before the Office of the President, which was dismissed. The CA, in its "Somera decision," declared the HLURB Arbiter's and Office of the President's decisions null and void for want of jurisdiction. Two separate petitions for review (G.R. No. 139099 and G.R. No. 139729) were filed with the Supreme Court assailing the Somera decision. Finally, when the HLURB Arbiter denied a motion for execution of the 1991 decision due to Agda's pending petition with the Office of the President, another petition was filed with the Supreme Court (G.R. No. 139631) to compel the issuance of the writ of execution. Procedural History: The Supreme Court consolidated five petitions. G.R. No. 137551 was dismissed as moot because the CA had already rendered the Somera decision. G.R. No. 139631 was dismissed for failure to exhaust administrative remedies, as the HLURB Rules provide for a petition for review to the Board of Commissioners and then to the Office of the President before resorting to the courts. G.R. Nos. 139099 and 139729 were granted, reversing the CA's Somera decision. The Supreme Court reinstated the HLURB Arbiter's decision dated February 20, 1991, as affirmed by the Board of Commissioners and the Office of the President. The Petition: The consolidated petitions sought various reliefs, including the dismissal of petitions for annulment of judgment, compelling the issuance of writs of execution, and reversal of the Court of Appeals' decision in the annulment case.
Issue(s)
Whether the Court of Appeals erred in annulling the decisions of the HLURB Arbiter and the Office of the President; and whether a petition for annulment of judgment under Rule 47 of the Rules of Court is the proper remedy to assail decisions of administrative agencies. Whether the denial of a motion for execution by the HLURB Arbiter is directly appealable to the Supreme Court without exhausting administrative remedies. Whether the Supreme Court should compel the issuance of a writ of execution when there are pending administrative appeals.
Ruling
The petitions in G.R. Nos. 137551 and 139631 are DISMISSED. The petitions in G.R. Nos. 139099 and 139729 are GRANTED, and the decision of the Court of Appeals dated June 30, 1999, is REVERSED and SET ASIDE. The decision of the Housing and Land Use Arbiter dated February 20, 1991, as affirmed by the Board of Commissioners and the Office of the President, is REINSTATED.
Ratio Decidendi
On the propriety of annulment of judgment and the application of Rule 47 (G.R. Nos. 139099 and 139729): The Supreme Court held that a petition for annulment of judgment under Rule 47 of the Rules of Court is specifically confined to decisions of the Regional Trial Court and cannot be availed of to annul decisions of administrative agencies like the HLURB Arbiter or the Office of the President. The Court emphasized that there is no remedy for the annulment of judgments of administrative bodies. Furthermore, even if treated as a petition for review under Rule 43, it should have been dismissed as no error of judgment was imputed to the HLURB and the Office of the President. The grounds of fraud and lack of jurisdiction are not the proper subject of a Rule 43 petition, which is for errors of judgment. The Court reiterated that the HLURB Arbiter and the Office of the President have jurisdiction over cases filed before them, citing Francisco Sycip, Jr. vs. Court of Appeals. On the exhaustion of administrative remedies (G.R. No. 139631): The Supreme Court dismissed the petition for failure to exhaust administrative remedies. The HLURB Rules of Procedure clearly outline a hierarchical appeal process: a decision of the Arbiter is reviewable by the Board of Commissioners, whose decision can then be appealed to the Office of the President. From the Office of the President, the aggrieved party can resort to the Court of Appeals. The Court stressed that direct resort to the Supreme Court is improper and premature when such administrative remedies are available and have not been pursued. The Supreme Court, as a court of last resort, should not be burdened with handling cases in the first instance when clear procedural remedies exist. On the mootness of the petition for mandamus (G.R. No. 137551): The Supreme Court dismissed the petition for mandamus as moot. The relief sought by the petitioner was to compel the Court of Appeals to resolve a motion to dismiss a petition for annulment of judgment. However, by the time the Supreme Court considered the petition, the Court of Appeals had already acted on the petition for annulment of judgment by rendering the "Somera decision." Therefore, the issue of compelling the CA to act on the motion to dismiss had become moot, as the CA had already rendered its decision on the underlying petition.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Court is confined to decisions of the Regional Trial Court and cannot be used to annul decisions of administrative agencies like the HLURB Arbiter or the Office of the President. Direct resort to the Supreme Court to compel the issuance of a writ of execution is improper and premature if administrative remedies have not been exhausted.