Manila Bankers Life Insurance Corporation v. Eddy Ng Kok Wei
REITERATIONFacts
The Antecedents: Eddy Ng Kok Wei, a Singaporean businessman, expressed his intention to purchase a condominium unit from Manila Bankers Life Insurance Corporation (petitioner). He paid a reservation fee and 90% of the purchase price. A Contract to Sell was executed, stipulating substantial completion and delivery within fifteen (15) months from February 8, 1989, or by May 8, 1990. The contract also stipulated a penalty of 1% of the total amount paid should petitioner fail to deliver the unit on the specified date. Procedural History: Petitioner informed respondent of substantial completion but reset the turnover date due to uncontrollable forces. Upon respondent's return to Manila, he found the unit still uninhabitable due to lack of water and electricity. Despite subsequent notices and respondent's return to the Philippines, the unit remained unlivable. Respondent demanded payment for damages, but petitioner ignored the demand. Respondent filed a complaint for specific performance and damages. During the pendency of the case, respondent accepted and occupied the unit on April 12, 1991, limiting his cause of action to damages. The Regional Trial Court (RTC) found petitioner liable for damages, ordering payment of 1% of the total amount paid, moral damages, exemplary damages, attorney's fees, and costs. The Court of Appeals (CA) affirmed the RTC's decision in toto. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari, assailing the CA's decision and resolution. Petitioner contended that the trial court had no jurisdiction over the case and that the CA erred in affirming the trial court's finding of unreasonable delay in the delivery of the condominium unit.
Issue(s)
Whether the Regional Trial Court (RTC) had jurisdiction over the case. Whether petitioner incurred unreasonable delay in the delivery of the condominium unit to respondent.
Ruling
The petition is DENIED. The assailed Decision dated March 26, 1999 and Resolution dated August 5, 1999 of the Court of Appeals are hereby AFFIRMED IN TOTO.
Ratio Decidendi
On the issue of jurisdiction: The Court held that jurisdiction over cases involving 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) under Presidential Decree No. 1344, as amended. The Court found that petitioner is estopped from assailing the trial court's lack of jurisdiction because petitioner actively participated in the proceedings before the RTC and the CA without raising the issue of jurisdiction. By submitting its case for decision and accepting the judgment if favorable, only to attack it for lack of jurisdiction when adverse, petitioner engaged in an undesirable practice. Its failure to raise the question of jurisdiction before the lower courts constituted a confirmation and ratification of the RTC's jurisdiction, placing petitioner in estoppel. On the issue of unreasonable delay: The Court reiterated that findings of fact by the trial court, when supported by substantial evidence and affirmed by the Court of Appeals, are given great weight. The question of whether petitioner incurred delay and is liable for damages is a factual issue. The Supreme Court's jurisdiction in a petition for review on certiorari under Rule 45 is limited to reviewing errors of law, not of fact, unless the factual findings are unsupported by evidence or the judgment is based on a misapprehension of facts. These exceptions were not present in this case, thus the factual findings of the lower courts regarding the delay were upheld.
Main Doctrine
A party who actively participates in court proceedings without raising the issue of jurisdiction is deemed estopped from assailing such lack of jurisdiction after submitting its case for decision.