Javellana v. Legarda
REITERATIONFacts
1. The Antecedents: Private respondent Benito Legarda filed a complaint for accion publiciana and sum of money against petitioners Spouses Ma. Carmen and Victor Javellana. The dispute arose from a Contract To Sell executed on December 11, 1992, for a lot located in Sampaloc, Manila. Petitioners were placed in possession of the lot upon execution of the contract. However, they allegedly defaulted in their monthly installment payments starting February 1995. Consequently, Legarda rescinded the contract on October 16, 1996, and offered to refund the cash surrender value of the payments made by the petitioners, contingent upon the restoration of the lot's possession. 2. Procedural History: The complaint was filed before the Regional Trial Court (RTC) of Manila, Branch 30, on December 6, 1996. Petitioners filed a motion to dismiss on March 16, 1998, questioning the RTC's jurisdiction. The RTC denied this motion in an Order dated September 30, 1998, and subsequently denied their motion for reconsideration on December 28, 1998. Petitioners then filed an Answer Ad Abundante Cautelam. Subsequently, petitioners filed a petition for certiorari with the Court of Appeals (CA) challenging the RTC's jurisdiction. The CA dismissed this petition on April 30, 1999, for being filed out of time, and denied their motion for reconsideration on June 9, 1999. 3. The Petition: The petitioners filed a petition for review on certiorari with the Supreme Court, assailing the CA's dismissal of their petition. They argue that the CA erred in dismissing their petition for being filed out of time, contending that procedural rules should not override substantial justice, especially when the issue involves jurisdiction. They further argue that the subject lot is a subdivision lot, placing it under the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB). The petition raises the issue of whether the failure to timely file the petition for certiorari amounts to estoppel despite the jurisdictional issue, and whether the RTC has jurisdiction over the subject matter. The Supreme Court, applying a subsequently amended procedural rule, found the petition to the CA to be timely filed and proceeded to rule on the jurisdictional issue, ultimately affirming the RTC's jurisdiction.
Issue(s)
Whether the failure to timely file the petition for certiorari amounts to estoppel despite the issue involving the jurisdiction of the respondent court. Whether the Regional Trial Court of Manila (Branch 30) has jurisdiction over the subject matter of the complaint filed by private respondent.
Ruling
The Supreme Court set aside the Resolutions of the Court of Appeals and affirmed the Orders of the trial court denying petitioners' motion to dismiss. The Court ruled that the RTC has jurisdiction over the case.
Ratio Decidendi
On the issue of timely filing and estoppel: The Court held that while the petition for certiorari was initially filed out of time under the 1997 Rules of Civil Procedure, the subsequent amendment to Section 4, Rule 65, which took effect on September 1, 2000, is applicable to pending cases. This amendment provides a 60-day period from notice of the judgment or denial of a motion for reconsideration. Counting from January 18, 1999 (receipt of denial of motion for reconsideration), the petition filed on March 19, 1999, was within the reglementary period. Therefore, the CA should have taken cognizance of the petition. However, instead of remanding the case, the Supreme Court opted to resolve the jurisdictional issue to avoid further delay. On the jurisdiction of the Regional Trial Court: The Court ruled in the negative regarding the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB). It reiterated the settled rule that jurisdiction over the subject matter is determined by the allegations in the complaint, not by the defendant's pleas or theories. Examining the complaint for Accion Publiciana and sum of money, the Court found no allegation that the subject lot was a subdivision lot as defined by law. The complaint described it as Lot No. 44, Plan 15, with a specific area and title, and indicated an ordinary sale on an installment basis. The Court noted that the Contract to Sell, even with a clause mentioning 'regular subdivision project,' did not sufficiently establish that the lot was a subdivision lot. The clause merely provided a condition under which petitioners could desist from payments without forfeiture, and it was uncertain if such conditions applied. The Court distinguished this from cases where the complaint explicitly alleges facts conforming to the definition of a subdivision project and lot under PD 957, which would then fall under HLURB's exclusive jurisdiction. Therefore, the RTC correctly assumed jurisdiction.
Main Doctrine
The determination of jurisdiction over the subject matter is based on the allegations in the complaint, not on the defenses raised by the defendant. A mere reference to a 'regular subdivision project' in a contract does not automatically vest jurisdiction in the HLURB if the complaint does not sufficiently allege facts to establish that the property is a subdivision lot as defined by law.