Badillo v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners alleged they were registered owners of lots adjoining a road lot (Lot 369-A-29), which connects their properties to the main road. This road lot was registered in the name of respondent Pedro del Rosario, with an annotation stating it could not be closed or disposed of without prior court approval. Petitioners claimed del Rosario sold a portion of this road lot to respondents Josefa Conejero and Ignacio Sonoron without court approval, leading to a partition and issuance of new titles. Del Rosario also allegedly sold his title to respondent Goldkey Development Corporation. Petitioners asserted the Register of Deeds violated the court order by registering these sales without judicial approval. Goldkey allegedly built fences, blocking ingress and egress. Petitioners prayed for the declaration of nullity of the sales and partition. Procedural History: Petitioners initially filed a complaint with the Office of the Building Official of Quezon City, which ruled against them, declaring the property a residential lot, not a road lot. This decision became final. Subsequently, petitioners filed a case for Annulment of Title and Damages with the Regional Trial Court (RTC) of Quezon City. The RTC dismissed the case for lack of jurisdiction, citing the prior ruling of the building official and the issuance of a development permit by the Housing and Land Use Regulatory Board (HLURB) to Goldkey. The Court of Appeals (CA) dismissed petitioners' appeal, holding that the case falls under the exclusive jurisdiction of the HLURB and that petitioners raised a pure question of law, which should have been appealed directly to the Supreme Court. The Petition: Petitioners filed a petition for certiorari with the Supreme Court, assailing the CA's dismissal of their appeal.
Issue(s)
Whether the appellate court acted without or in excess of jurisdiction or with grave abuse of discretion by dismissing petitioners’ appeal on the ground that jurisdiction does not lie with the regular courts but with the HLURB; Whether the Court of Appeals acted without or in excess of jurisdiction or grave abuse of discretion by dismissing petitioners’ appeal on the ground that petitioners did not assign any error of fact; Whether a petition for certiorari under Rule 65 of the 1997 Rules of Civil Procedure is the proper remedy for petitioners.
Ruling
The Supreme Court dismissed the petition and affirmed the decision of the Court of Appeals. The Court held that the HLURB has exclusive jurisdiction over the case and that the appeal to the Court of Appeals was improper as it involved a pure question of law.
Ratio Decidendi
On the issue of jurisdiction: The Court affirmed the ruling that the HLURB has exclusive jurisdiction over the subject matter. Presidential Decree No. 957, as amended by PD 1344 and implemented by Executive Orders 648 and 90, vests the HLURB with the exclusive authority to hear and decide cases involving specific performance of contractual and statutory obligations of subdivision owners and developers. The petitioners' claim that the road lot was illegally sold and partitioned, thereby blocking their access, constitutes a claim for specific performance, which falls squarely within the HLURB's specialized competence. The Court reiterated that questions relating to the conversion or disposition of subdivision lots are properly cognizable by the HLURB, not the regular courts, citing Cristobal v. Court of Appeals. The annotation on the title, while requiring court approval at the time of its entry, was implicitly modified by subsequent laws granting exclusive jurisdiction to the HLURB over such matters. The Court emphasized that split jurisdiction is not favored, and administrative agencies with quasi-judicial functions are deemed to have jurisdiction over controversies within their specialization. On the nature of the appeal to the Court of Appeals: The Court found that the petitioners' appeal to the Court of Appeals involved a pure question of law. The sole issue raised in their Appellants' Brief was whether the trial court erred in holding that it lacked jurisdiction over the subject matter. A question of law arises when the doubt or controversy concerns the correct application of law or jurisprudence to a set of facts, without requiring an examination of the probative value of the evidence. Since the issue of jurisdiction is a question of law, the appeal should have been filed directly with the Supreme Court via a petition for review on certiorari under Rule 45, not as an ordinary appeal under Rule 41 to the Court of Appeals. Section 2(c) of Rule 41 explicitly states that appeals raising only questions of law shall be taken to the Supreme Court. The Court of Appeals correctly dismissed the appeal pursuant to Section 2, Rule 50 of the Rules of Court, which mandates the dismissal of appeals to the CA that raise only questions of law. On the propriety of the petition for certiorari: The Court held that a petition for certiorari under Rule 65 is not a substitute for a lost appeal, especially when the loss is due to the petitioner's own error in choosing the wrong mode of appeal. The special civil action for certiorari is a remedy of last resort, available only when there is no appeal or plain, speedy, and adequate remedy in the ordinary course of law. In this case, petitioners had a proper remedy, which was an appeal by certiorari to the Supreme Court under Rule 45, but they chose to file an ordinary appeal with the Court of Appeals. Their failure to avail of the correct remedy does not warrant the liberal application of the rules to allow certiorari as a substitute for a lost appeal. The Court reiterated that certiorari is not and cannot be a substitute for an appeal, particularly when the loss of the appeal is occasioned by the petitioner's own negligence or error.
Main Doctrine
The Housing and Land Use Regulatory Board (HLURB) has exclusive jurisdiction over cases involving specific performance of contractual and statutory obligations related to subdivision development, including disputes over the conversion or disposition of subdivision road lots. Appeals raising purely questions of law from Regional Trial Court decisions should be filed directly with the Supreme Court via petition for review on certiorari, not with the Court of Appeals.