Case Digest (G.R. No. L-50444)
Facts:
In Antipolo Realty Corporation vs. National Housing Authority, decided on August 31, 1987, petitioner Antipolo Realty Corporation granted Jose Hernando a Contract to Sell over Lot No. 15, Block IV of the Ponderosa Heights Subdivision on August 18, 1970. Hernando transferred his rights to Virgilio A. Yuson on August 28, 1974, under a Deed of Assignment and Substitution of Obligor, whereby Yuson assumed all payment obligations, including arrears. Under Clause 17 of the Contract to Sell, Antipolo Realty undertook to complete subdivision improvements (curbs, drainage, paving, water, electrical, landscaping, park, security) within two years, and Yuson could suspend installments with no penalties until such improvements were finished. Yuson halted payments after August 1972, citing unmet improvements. In October and November 1976, Antipolo Realty notified him that development was complete and demanded payment of arrears from September 1972 to October 1976 amounting to ₱16,994.73. YusoCase Digest (G.R. No. L-50444)
Facts:
- Contract to Sell and Beautification Clause
- On August 18, 1970, Antipolo Realty Corporation (ARC) sold Lot No. 15, Block IV, Ponderosa Heights Subdivision, Antipolo, Rizal to Jose Hernando under a Contract to Sell.
- Clause 17 of the Contract required ARC to complete specified subdivision improvements (roads, drainage, water, electrical, landscaping, park, security) within two years, or allow the buyer to suspend installments without penalty until completion.
- Assignment and Suspension of Payments
- On August 28, 1974, Hernando assigned all rights and obligations to Virgilio Yuson, who paid arrears up to August 1972 and then suspended installments due to ARC’s failure to complete improvements.
- Yuson paid post-improvement installments only after verifying ARC’s October 1976 claim of completion; he refused to pay arrears for September 1972–October 1976.
- Contract Rescission and Administrative Complaint
- ARC rescinded the Contract to Sell and declared forfeiture of all payments for Yuson’s refusal to pay the alleged arrears of ₱16,994.73.
- On May 10, 1977, Yuson filed NHA Case No. 2123; ARC’s motion to dismiss was denied (Feb 7, 1978), hearing held without ARC’s attendance, and on March 9, 1978 the NHA ordered reinstatement of the contract with conditions (statement of account, no penalty interest, 60 days to pay arrears).
- Appeals and Supreme Court Intervention
- ARC’s motion for reconsideration was denied (June 28, 1978); its certiorari petition to the Supreme Court was denied (Dec 11, 1978; recon. denied Jan 29, 1979).
- Appeal to the Office of the President was dismissed (March 9, 1979). The Supreme Court then decided on the merits of ARC’s petition (G.R. No. 50444).
Issues:
- Whether the National Housing Authority (NHA) had jurisdiction to hear and decide Yuson’s complaint.
- Whether the NHA acted in excess of its jurisdiction or committed grave abuse of discretion.
- Whether ARC was denied due process in the NHA proceedings.
- Whether installments during the suspension period (September 1972–October 1976) were due, demandable, and subject to forfeiture.
- Whether ARC could validly rescind the Contract to Sell and retain prior installment payments under Clause 7.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)