Genato v. Viola
REITERATIONFacts
The Antecedents: A complaint was filed with the Housing and Land Use Regulatory Board (HLURB) by the Villa Rebecca Homeowners Association, Inc. against Spouses William and Rebecca Genato. The complaint, verified by 34 individuals including Rita Viola, alleged that the complainants entered into Contracts to Sell and/or Lease Purchase Agreements with the Sps. Genato for housing units. After an HLURB cease and desist order (CDO) enjoining amortization payments was lifted, the Sps. Genato refused to accept payments and demanded a lump sum of accrued amortizations during the CDO's effectivity. The complainants prayed for various reliefs, including acceptance of payments without penalty, correct interest computation, correction of construction deficiencies, provision of deep wells, maintenance of street lights, adherence to contract price, and accountability for unregistered units. Procedural History: The Housing Arbiter ordered complainants to resume payments and respondents to correct construction deficiencies and provide water facilities. The HLURB Board of Commissioners modified this, ordering complainants to pay the remaining balance with 3% monthly interest and respondents to accept payments, provide drainage, water facilities, and reimburse certain expenses. This decision became final and executory. A writ of execution was issued, leading to the seizure of Rita Viola's two delivery trucks and 315 sacks of rice. Viola filed a motion to quash execution. The trucks were released, but the rice was auctioned, with petitioner Rebecca Genato being the highest bidder at ₱189,000.00. Arbiter Torres denied Viola's motion and ordered her to pay ₱739,133.31. The HLURB, First Division, granted Viola's motion to quash, set aside the Arbiter's order, and directed respondents to credit Viola with ₱318,500.00 for the seized rice. The Office of the President affirmed this decision, as did the Court of Appeals. The Petition: The Sps. Genato filed a petition for review, assailing the CA's decision which affirmed the Office of the President and HLURB. They questioned whether the HLURB acquired jurisdiction over Rita Viola, whether the HLURB could rule on lack of jurisdiction after the decision became final, whether Viola could claim an amount higher than the sheriff's certificate of sale, and whether the rule on binding findings of fact was applicable.
Issue(s)
Whether the Court of Appeals erred in ruling that the HLURB has not acquired jurisdiction over the person of respondent Rita Viola. Whether after the decision has become final and executory, the HLURB could still rule on the lack of jurisdiction over the person of Rita Viola. Whether respondent Viola can claim an amount higher than what appears on the Sheriff's Certificate of Sale. Whether the rule that findings of facts and conclusions of any adjudicative body should be considered as binding and conclusive on the appellate court, is applicable in the case at bar.
Ruling
The Supreme Court granted the petition, reversed and set aside the Court of Appeals' decision, and reinstated and affirmed the December 15, 2000 Order of Arbiter Marino Bernardo M. Torres.
Ratio Decidendi
On the issue of whether the HLURB acquired jurisdiction over Rita Viola: The Supreme Court held that the HLURB did acquire jurisdiction over Rita Viola. It emphasized that it is the allegations in the complaint, not its title, that are controlling. Respondent Viola, though not named in the title, caused the preparation and verification of the complaint, and the body of the complaint clearly indicated she was one of the complainants. Her active participation and verification of the complaint constituted a voluntary submission to the HLURB's authority, thereby conferring jurisdiction over her person. The Court noted that any defect in the designation of parties could have been summarily corrected at any stage of the action without prejudice to the adverse party, as the error was merely formal and not substantial. Furthermore, Viola was estopped from claiming lack of jurisdiction, as she had consistently acted as a complainant until the judgment became final and executory, inducing the petitioners to rely on her participation. On the issue of whether the HLURB could rule on lack of jurisdiction after the decision became final and executory: The Supreme Court ruled that a final and executory judgment becomes immutable and unalterable, with limited exceptions not present in this case. However, the premise of this issue was flawed because the Court found that the HLURB did acquire jurisdiction over Viola from the outset. Therefore, the decision was not void, and the issue of modifying a final judgment due to lack of jurisdiction did not apply in the manner argued by Viola. The Court reiterated that the HLURB decision, having become final and executory, could no longer be modified, and the execution of such a judgment is a ministerial duty. On the issue of whether respondent Viola can claim an amount higher than what appears on the Sheriff's Certificate of Sale: The Supreme Court held that the amount to be credited to Viola's account for the seized rice should be the actual bid price at the public auction, as per the Sheriff's Certificate of Sale. The Court cited Section 19, Rule 39 of the Rules of Court, which mandates that sales of property under execution must be made to the highest bidder. Therefore, the highest bid submitted, which was ₱189,000.00 by Rebecca Genato, is the amount that should be credited to Viola's account, not the ₱318,500.00 valuation claimed by Viola. On the applicability of the rule on binding findings of fact: The Supreme Court clarified that while findings of fact by adjudicative bodies are generally binding, this holds true only when such findings are supported by substantial evidence. In this case, the Court found insufficient evidential support for the HLURB's conclusion that it did not acquire jurisdiction over Viola. Therefore, the Court was justified in disturbing the HLURB's findings on this specific point, as the doctrine of conclusiveness of findings of fact is not absolute and can be set aside when there is a clear showing of lack of substantial evidence or grave abuse of discretion.
Main Doctrine
Jurisdiction over the person can be acquired by voluntary submission, and a party who actively participates in proceedings before a tribunal, even if not formally impleaded in the title, is estopped from later claiming lack of jurisdiction once the judgment becomes final and executory.