Francel Realty Corp. v. Sycip
REITERATIONFacts
The Antecedents: Francel Realty Corporation (petitioner) and Ricardo T. Sycip (respondent) entered into a contract to sell a house and lot. Respondent made a down payment, and the title was transferred to his name. However, respondent refused to pay the balance, citing defects in the townhouse and invoking Presidential Decree No. 957 (PD 957). Petitioner claimed the down payment was applied to rentals and demanded reconveyance, suffering damages. Procedural History: Respondent filed a motion to dismiss the reconveyance and damages case filed by petitioner on the ground of lack of jurisdiction, which the trial court initially denied. Respondent continued to invoke lack of jurisdiction in his Answer and during trial, also pointing to a pending case before the Housing and Land Use Regulatory Board (HLURB) for unsound real estate business practices. The trial court eventually dismissed the case for lack of jurisdiction. The Court of Appeals (CA) affirmed the dismissal, holding that the case fell under the exclusive jurisdiction of the HLURB as it involved rights and obligations under PD 957. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's affirmation of the trial court's dismissal, arguing that dismissal on the ground of lack of jurisdiction was improper after a full-blown trial, and that respondent failed to secure HLURB authority to stop payment of monthly rentals.
Issue(s)
Whether the lower court could dismiss the case after a full-blown trial on the ground of lack of jurisdiction. Whether the lower court could dismiss the case despite the respondent not securing HLURB authority to stop payment of monthly rentals.
Ruling
The Petition is denied, and the assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of dismissal for lack of jurisdiction after a full-blown trial: The Court reiterated the general rule that lack of jurisdiction over the subject matter may be raised at any stage of the proceedings, even on appeal, as jurisdiction is conferred by law and cannot be acquired by consent or estoppel. The ruling in Tijam v. Sibonghanoy, which allowed dismissal on appeal due to laches, was clarified as an exception applicable only to exceptional circumstances where the objection to jurisdiction is raised so belatedly as to warrant the presumption of abandonment. In this case, the respondent consistently challenged the trial court's jurisdiction from his motion to dismiss, through his answer, and during the trial, thus defeating the claim of estoppel by laches. The Court emphasized that jurisdiction is determined by the averments of the complaint, not by the defenses raised. Furthermore, the nature of the case, involving rights and obligations under PD 957, falls under the exclusive jurisdiction of the HLURB, as previously established in similar cases involving the petitioner. The Court also noted that petitioner's attempt to file the case in regular courts was a circumvention of the law and a potential subversion of buyers' rights. On the issue of authority to stop payment of monthly rentals: The Court ruled that Section 23 of PD 957, which allows a buyer to stop further payments after due notice to the owner or developer due to failure to develop, does not require prior clearance from the HLURB. The Court distinguished this from Section 18 of PD 957, which explicitly requires written consent or approval from the HLURB for certain transactions. The Court held that an implementing rule cannot expand or contradict the law it seeks to implement, and thus, the cited implementing rule requiring HLURB clearance was deemed void. The Court emphasized that the intent of PD 957 is to protect buyers, and requiring HLURB clearance would hinder this purpose. The right to stop payment, upon due notice, is immediately effective and serves as a valid defense against claims for payment or reconveyance.
Main Doctrine
Lack of jurisdiction over the subject matter may be raised at any stage of the proceeding, even on appeal, as jurisdiction is conferred by law and cannot be acquired by consent or estoppel, except in exceptional circumstances analogous to Tijam v. Sibonghanoy. An implementing rule cannot expand or contradict the law it seeks to implement.