Park Developers v. Daclan
REITERATIONFacts
The Antecedents: On September 24, 2003, respondent Elizabeth D. Daclan purchased a family estate memorial lot from petitioner Park Developers Incorporated (PDI) for P708,000.00, payable in installments. Respondent had paid P457,760.74 by the time the case was filed. In 2005, respondent discovered that the Housing and Land Use Regulatory Board (HLURB) had not issued a Certificate of Registration or License to Sell to PDI. Consequently, on January 13, 2006, respondent filed a case for Annulment of Contract with Damages against PDI and its corporate officers. Procedural History: The Regional Trial Court (RTC), Branch 67, Pasig City, rendered a decision on March 31, 2011, annulling the agreement, ordering petitioners to return the P457,760.74 paid by respondent with legal interest, and awarding moral damages, exemplary damages, and attorney's fees. Petitioners appealed this decision to the Court of Appeals (CA) under Rule 41, raising only the issue of jurisdiction. On August 12, 2013, the CA dismissed the appeal, citing Section 2, Rule 50 of the Rules of Court, as the appeal raised a pure question of law, which should have been filed directly with the Supreme Court via a petition for review on certiorari under Rule 45. The CA denied petitioners' motion for reconsideration on February 10, 2014. The Petition: Petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to set aside the CA's dismissal. They argue that the CA erred in dismissing their appeal without ruling on the substantive issue of whether the HLURB, not the RTC, had primary jurisdiction. Petitioners contend that the RTC's judgment is void due to lack of jurisdiction and ask the Supreme Court to decide the issue of jurisdiction over contracts for memorial lots when the developer lacks the required licenses. The core of their argument is that the CA should have addressed the jurisdictional question rather than dismissing the appeal on a procedural technicality.
Issue(s)
Whether the Court of Appeals erred in dismissing the petitioners' appeal for raising a pure question of law. Whether the Regional Trial Court has jurisdiction over a complaint for annulment of contract involving the purchase of memorial lots, despite the primary jurisdiction of the HLURB. Whether the RTC's decision annulling the contract and awarding damages is valid.
Ruling
The Supreme Court denied the petition, affirming the RTC's decision in its entirety. While the CA correctly dismissed the appeal on procedural grounds, the Court resolved the substantive issue in the interest of justice. The Court held that the RTC had jurisdiction over the case, and its decision annulling the contract and awarding damages was valid.
Ratio Decidendi
On the dismissal of the appeal by the Court of Appeals: The Court affirmed the CA's dismissal of the petitioners' appeal pursuant to Section 2, Rule 50 of the Rules of Court. The petitioners' appeal to the CA raised only a pure question of law, specifically regarding the jurisdiction of the RTC. Under Section 2(c), Rule 41 of the Rules of Court, appeals involving only questions of law must be taken to the Supreme Court by way of a petition for review on certiorari under Rule 45. An appeal erroneously taken to the CA raising only questions of law shall be dismissed outright. Therefore, the CA's action was procedurally correct. On the jurisdiction of the Regional Trial Court: The Court acknowledged that the Housing and Land Use Regulatory Board (HLURB) has primary jurisdiction over disputes involving memorial lots, as indicated by various laws and resolutions, including the more recent RA 11201 and its Implementing Rules and Regulations (IRR). However, the Court clarified that at the time the complaint was filed, the jurisdictional boundaries were not as clearly delineated, and the RTC, being a court of general jurisdiction, could entertain such cases unless specifically vested in another tribunal. The Court noted that the specific provisions of PD 1344, which grants exclusive jurisdiction to the HLURB, were not as comprehensive regarding memorial parks as they are now under the 2017 Rules and RA 11201. Therefore, the RTC's exercise of jurisdiction was upheld, especially since the issue was raised for the first time on appeal and the RTC had already rendered a decision. On the validity of the RTC's decision: The Court found no reason to disturb the RTC's decision. The petitioners did not question the factual findings of the RTC, implying an admission of liability. The RTC correctly annulled the "Application for Continual Use" because the respondent's consent was vitiated by mistake, stemming from PDI's misrepresentation in advertisements and the lack of authority to sell the lots. The award of moral and exemplary damages was justified by the respondent's suffering and the petitioners' bad faith. The award of attorney's fees was also proper, as the respondent was compelled to litigate to protect her interests. Thus, the RTC's decision was affirmed in its entirety.
Main Doctrine
While the Housing and Land Use Regulatory Board (HLURB) has primary jurisdiction over disputes involving memorial lots, the Regional Trial Court (RTC) retains jurisdiction if the case does not exclusively fall within the HLURB's specialized competence, especially when the issue of jurisdiction is raised for the first time on appeal and the RTC's decision has already been rendered. Furthermore, an appeal raising only questions of law from an RTC decision should be filed with the Supreme Court via petition for certiorari under Rule 45, not an ordinary appeal to the Court of Appeals under Rule 41.