Delta Development v. Housing and Land Regulatory Board
REITERATIONFacts
The Antecedents: Petitioner, Delta Development & Management Services, Inc. (Delta), a real estate developer, is the subject of multiple complaints filed by lot buyers before the Housing and Land Regulatory Board (HLURB). These complaints allege violations of Presidential Decree No. 957 and Batas Pambansa Blg. 220. One such complaint, filed by Elizabeth Nicolas, resulted in a decision by Arbiter Raymundo A. Foronda ordering Delta to pay the buyer a balance, deliver a title free from encumbrances, and pay damages and costs. Procedural History: Following the filing of several complaints against Delta, an employee of the HLURB, Jun Labapi, allegedly admitted to preparing these complaints for the lot buyers. This revelation prompted Delta to file a Petition for Prohibition with the Court of Appeals, seeking to enjoin the HLURB from further proceedings. The Court of Appeals dismissed this petition, citing the doctrine of exhaustion of administrative remedies and Delta's failure to implead the complainants and serve them with copies of the petition. A subsequent motion for reconsideration was also denied. The Petition: Delta seeks review of the Court of Appeals' resolutions via a Petition for Review on Certiorari under Rule 45. The petition argues that the Court of Appeals erred in applying the doctrine of exhaustion of administrative remedies, asserting that the nature of the petition for prohibition, which challenged the proceedings rather than a specific decision, made this doctrine inapplicable. Delta also contends that the HLURB employee's alleged involvement in preparing the complaints constituted a denial of due process, thereby justifying the bypass of administrative remedies.
Issue(s)
Whether the Court of Appeals correctly ruled that the instant petition is a violation of the doctrine of exhaustion of administrative remedies. Whether the respondent committed grave abuse of discretion amounting to lack or excess of jurisdiction in having been involved in the preparation of the complaints filed by the complaining buyers against the petitioner.
Ruling
The petition is DENIED, and the resolutions dated 25 July 2000 and 7 November 2000 of the Court of Appeals in CA-G.R. SP No. 59694 are AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the Issue of Exhaustion of Administrative Remedies: The Supreme Court affirmed the CA's ruling that the petition violated the doctrine of exhaustion of administrative remedies. The Court emphasized that prohibition is an extraordinary remedy and cannot be resorted to when ordinary and usual remedies provided by law are adequate and available. It stated that prohibition is granted only where no other remedy is available or sufficient to afford redress. The Court noted that the 1996 HLURB Rules of Procedure provided a remedy for alleged partiality of an arbiter through a written objection, which DELTA failed to avail itself of. The Court found that DELTA did not bring the alleged underhanded practice of the HLURB employee to the attention of the arbiter, thus depriving the arbiter of the opportunity to assess the situation and determine if the proceedings had been compromised. The Court concluded that DELTA took upon itself to decide that the determination of all cases had been affected by the irregularity without exhausting available remedies. On the Issue of Grave Abuse of Discretion and Due Process: The Supreme Court rejected DELTA's contention that the HLURB employee's alleged involvement in preparing the complaints constituted a denial of due process, making the exhaustion of remedies inapplicable. The Court held that DELTA should not be allowed to claim denial of due process based solely on its perception of a conspiracy when it failed to raise the matter before the arbiters who were in a position to correct any irregularity. The Court further stated that DELTA's prayer for an injunction to enjoin the HLURB arbiters from hearing the cases smacks of an absolute denial of due process for the complainants, as it would foreclose the avenue through which their complaints could be heard. The Court reiterated that a writ of prohibition will not be issued against an inferior court unless its attention has been called to the alleged lack or excess of jurisdiction, a prerequisite that DELTA failed to meet.
Main Doctrine
A petition for prohibition cannot be resorted to when ordinary and usual remedies provided by law are adequate and available. Prohibition is granted only where no other remedy is available or sufficient to afford redress. Furthermore, a writ of prohibition will not be issued against an inferior court unless its attention has been called to the alleged lack or excess of jurisdiction.