Bank of the Philippine Islands v. ALS Management & Development Corp.
REITERATIONFacts
The Antecedents: BPI Investment Corporation (now petitioner BPI) filed a complaint for a Sum of Money against ALS Management and Development Corporation (respondent) for unpaid advances amounting to ₱26,300.45 for the expenses in issuing and registering the Condominium Certificate of Title for Unit E-4A of the Twin Towers Condominium. Respondent alleged that petitioner increased the amount of advances in contravention of PD 957 and that the unit suffered from various defects and deficiencies, contrary to petitioner's warranties in its sales propaganda. Procedural History: The Regional Trial Court (RTC) ordered respondent to pay petitioner ₱26,300.45 for registration expenses and ordered petitioner to correct defects in the unit and pay respondent damages for completion work and unearned income. The Court of Appeals (CA) affirmed the RTC decision in toto. The Supreme Court reviewed the case upon petition by BPI. The Petition: Petitioner sought to set aside the CA decision, raising issues of jurisdiction, misapprehension of facts, and conjectural award of damages.
Issue(s)
Whether the trial court had jurisdiction over respondent's counterclaims. Whether the Court of Appeals erred in its findings of fact and award of damages regarding warranties, representations, storage facilities, delay in delivery, condominium defects, reimbursement for completion work, and unearned lease income. Whether the award of damages by the Court of Appeals was conjectural, and the appropriate remedy for established damages.
Ruling
The petition is partly meritorious. The Supreme Court modified the CA decision, deleting certain awards and ordering petitioner to pay temperate damages.
Ratio Decidendi
On the Issue of Jurisdiction: The Supreme Court held that the Housing and Land Use Regulatory Board (HLURB), not the RTC, has exclusive jurisdiction over respondent's counterclaims for specific performance and damages, as provided by PD No. 957 and PD No. 1344. However, the Court ruled that petitioner was barred by estoppel and laches from raising this issue for the first time on appeal, as it had voluntarily submitted to the RTC's jurisdiction and participated in the proceedings. The Court emphasized that parties cannot accept favorable judgments while rejecting unfavorable ones based on jurisdiction. On the Warranties and Representations in the Brochure, Storage Facilities, Damages for Delay in Delivery, Condominium Defects, Reimbursement for Completion Work, and Unearned Lease Income: The Court addressed several aspects of the Court of Appeals' findings. It affirmed that the brochure's particulars formed part of the sales warranties, but deleted the award for storage facilities due to lack of pleading and evidence. The Court also deleted the award for unearned income due to delay in delivery due to a lack of evidence. The Court affirmed the existence of condominium defects but clarified the balcony's intended use. The Court agreed that reimbursement for completion work was not sufficiently proven. Finally, the Court recognized damages due to a lessee vacating but deemed the award for unearned income speculative, awarding temperate damages instead. On the Conjectural Nature of Damages and Appropriate Remedy: The Court deleted specific awards for damages that were deemed speculative or insufficiently proven, such as the ₱136,608.75 for unearned income due to delay and the award for 21 months of alleged unearned lease income. However, for the unearned lease income, the Court awarded ₱51,000 as temperate damages, equivalent to three monthly rentals, as a reasonable amount under the circumstances where damages were proven but the exact amount was not.
Main Doctrine
A party who voluntarily submits to the jurisdiction of a court and participates in the proceedings until an unfavorable judgment is rendered may be barred by estoppel from questioning the court's jurisdiction. Furthermore, the Housing and Land Use Regulatory Board (HLURB) has exclusive jurisdiction over claims involving specific performance and damages filed by condominium unit buyers against project developers under PD 957 and PD 1344.