Tri-Corp Land v. Greystone
REITERATIONFacts
The Antecedents: Greystone Corporation (Greystone) executed a Contract to Sell with Tri-Corp Land & Development, Inc. (Tri-Corp) for a condominium unit for ₱13,500,000. Tri-Corp was denied membership and gate passes by the San Miguel Village Homeowner’s Association (SMVHA) because the construction of the condominium project violated village restrictions. SMVHA filed a case against Greystone before the Housing and Land Use Regulatory Board (HLURB) for this violation. Tri-Corp intervened in this case and also filed a separate petition with the HLURB for suspension and cancellation of Greystone's license to sell. Greystone filed an ejectment suit against Tri-Corp for non-payment, leading to Tri-Corp's ejection. Tri-Corp also filed a petition before the Regional Trial Court (RTC) of Makati City, sitting as a Land Registration Court, for correction of errors/misrepresentation in the Master Deed. Procedural History: The RTC dismissed Tri-Corp's petition for lack of jurisdiction, ruling that the case falls under the exclusive jurisdiction of the HLURB pursuant to PDs 987 and 1344. Tri-Corp's motion for reconsideration was denied. The Court of Appeals affirmed the RTC's dismissal and denied Tri-Corp's motion for reconsideration. Tri-Corp filed a petition for certiorari with the Supreme Court, alleging grave abuse of discretion by the Court of Appeals. The Petition: Tri-Corp alleged that the Court of Appeals committed grave abuse of discretion in (a) declaring its motion for reconsideration filed out of time, (b) declaring Tri-Corp not a party in interest, and (c) affirming the RTC's dismissal for lack of jurisdiction, despite the case allegedly involving cancellation of inscriptions and titles within the RTC's land registration jurisdiction.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in declaring Tri-Corp's motion for reconsideration filed out of time. Whether the Court of Appeals committed grave abuse of discretion in declaring Tri-Corp not a party in interest. Whether the Court of Appeals committed grave abuse of discretion in affirming the RTC's dismissal of the case for lack of jurisdiction.
Ruling
The Supreme Court dismissed the petition for certiorari. It found that the Court of Appeals did not commit grave abuse of discretion. The Court affirmed the dismissal of Tri-Corp's petition for lack of jurisdiction, holding that the case falls under the exclusive jurisdiction of the HLURB.
Ratio Decidendi
On the issue of the motion for reconsideration being filed out of time: The Court held that the Court of Appeals did not commit grave abuse of discretion. The reckoning period for filing the motion for reconsideration was the date of receipt by Tri-Corp's mailbox, not the date its representative, Solita S. Jimenez-Paulino, personally received it. The Court emphasized that Tri-Corp, not its representative, was the petitioner in the case. Therefore, the motion filed on July 13, 2004, after receipt by the mailbox on June 16, 2004, was indeed filed out of time, as the period to file would have expired on July 1, 2004. On the issue of Tri-Corp not being a party in interest: The Court found no grave abuse of discretion. The Court of Appeals correctly pointed out that the Contract to Sell contained a stipulation allowing Greystone to rescind the contract and forfeit payments as liquidated damages in case of default. Since Greystone had rescinded the contract due to Tri-Corp's failure to pay, Tri-Corp was no longer considered a party in interest with legal standing to pursue the case. On the issue of jurisdiction: The Court affirmed the Court of Appeals' decision that the RTC lacked jurisdiction. Presidential Decree No. 1344 explicitly grants the National Housing Authority (now HLURB) exclusive jurisdiction over cases involving unsound real estate business practices, claims by buyers against developers, and specific performance of contractual and statutory obligations. Tri-Corp's petition, which sought the cancellation of an annotation on titles and a condominium certificate of title based on allegations of Greystone's misrepresentations in project registration to circumvent laws, clearly falls under the definition of unsound real estate business practices. The HLURB possesses the technical expertise to resolve such complex issues related to real estate development and registration, making its jurisdiction exclusive in this matter.
Main Doctrine
The Housing and Land Use Regulatory Board (HLURB) has exclusive jurisdiction over cases involving unsound real estate business practices, claims by condominium unit buyers against project owners, and specific performance of contractual and statutory obligations by developers, as provided under Presidential Decree No. 957 and Presidential Decree No. 1344. A petition seeking cancellation of annotations on titles and condominium certificates of title, based on allegations of misrepresentation in project registration, falls within the exclusive jurisdiction of the HLURB.