G.R. No. 156439 - Calara vs. Francisco

Petitioners: Clemencia Calara and her children, who collectively own the Lophcal (Calara) Subdivision in Brgy. Anos, Los Baños, Laguna.
Respondents: Teresita Francisco, Jesus Francisco, and Gaudencio Navarro (among other buyers), involved in disputes relating to subdivisions and contractual obligations.

On 28 April 1982, a group of buyers (including Gaudencio Navarro and Jesus Francisco) filed a letter-complaint before the then Human Settlement Regulatory Commission (HSRC) for alleged violations of P.D. 957.
The complaint pointed out deficiencies such as the absence of a drainage system, unfinished curb and gutter, undeveloped roads, and abandoned electrical facilities.
Clemencia Calara, who had been named respondent in that complaint, filed an answer on 11 July 1982 claiming that the subdivision was exempt from P.D. 957 and contended that the issues raised related to a partitioning of the land.

On 29 July 1982, petitioners filed a complaint for unlawful detainer against respondents (specifically targeting Teresita and Jesus Francisco) in Civil Case No. 993 at the Municipal Court of Los Baños.
A separate complaint for unlawful detainer was also filed against Gaudencio Navarro as Civil Case No. 994.
In their 29 January 1990 amended complaint, petitioners alleged that in 1976 an offer to purchase Lot No. 23 (250 square meters) of the Lophcal Subdivision was made at P80.00 per square meter, supported by an advance payment of P8,093.00.
They further claimed that respondents, after constructing a house, refused both to execute a contract to sell and to continue making installment payments, despite receiving demand letters on 20 March 1979 and 27 March 1982 to vacate the property.

On 26 August 1982, respondents and Gaudencio Navarro jointly moved to dismiss the complaint, arguing lack of jurisdiction on the basis that another action (pending before the HSRC) involved the same cause and parties, and contending that the complaint did not state a cause of action.
The Municipal Court (later reorganized as a Municipal Trial Court, MTC) denied the motion to dismiss in its 28 June 1983 resolution.
A motion for reconsideration was filed on 30 June 1983, which was rendered moot by the subsequent effectivity of the Rules on Summary Procedure.
Meanwhile, the HSRC (later functioning under the HLURB) rendered a decision on 4 June 1985 in HLURB Case No. REM-060482-1043 ordering Calara to cease selling unsold lots until registration and licensing were secured, to develop the subdivision within four months, and imposed an administrative fine of P5,000.00.

Respondents, along with Gaudencio Navarro, filed their answer on 5 June 1989, denying the allegations and asserting that respondents had ceased paying monthly amortizations due to petitioners’ non-performance in developing the subdivision.
The MTC issued a decision on 6 October 1999 in Civil Case No. 993 finding no perfected contract of sale and ruling in favor of petitioners by ordering ejectment, demolition of structures, turnover of possession, and award of damages and attorney’s fees.
The RTC of Calamba, Laguna subsequently affirmed the MTC decision on 23 May 2000 in Civil Case No. 2866-99-C.
Respondents, despite procedural lapses (e.g., late answer and position paper submissions, failure to file a supersedeas bond), elevated the case through appeal with a petition for review, which culminated in the CA’s issuance of a writ of preliminary injunction.

On 12 April 2002, the Special Seventh Division of the Court of Appeals (CA) reversed the decisions of the MTC and RTC by dismissing the complaint for unlawful detainer.
The CA ruled that the dispute, centered on the failure to execute a contract to sell and the stoppage of installment payments, involves issues under P.D. 957 and is thus exclusively within the jurisdiction of the HLURB.
Furthermore, the CA cited prior decisions (e.g., Francel Realty Corporation vs. Court of Appeals) and statutes, emphasizing that even if the procedural lapses existed, they were not grounds to override the exclusive regulatory jurisdiction conferred on the HLURB.

The controversy involves determining whether the dispute is a simple ejectment/unlawful detainer action or one that requires the adjudication of contractual performance issues under P.D. 957.
The case raises questions regarding the perfection of a contract for sale and the rights of the buyer to withhold further payments due to the seller’s alleged failure to develop the subdivision.
The exclusive jurisdiction of the HLURB in such matters was underscored by regulatory and policy considerations aimed at ensuring uniformity in the real estate trade and business.

Whether the HLURB (formerly the HSRC) has exclusive original jurisdiction to determine the existence and perfection of the contract to sell, thereby resolving disputes arising from installment sales under P.D. 957.
Whether the regular courts (MTC, RTC, and CA) have jurisdiction in cases that intertwine ejectment issues with disputed installment payments and alleged non-development of a subdivision.

Whether respondents retain legal personality to pursue their petition for review despite alleged procedural lapses in their prior filings before the MTC, RTC, and CA.
Whether such procedural lapses (e.g., late filing of answers/position papers, failure to post a supersedeas bond) should preclude the substance of respondents’ appeal.

Whether a perfected contract to sell exists between petitioners and respondents for Lot No. 23, given that the parties allegedly agreed on price, terms, and payment conditions.
Whether respondents’ stoppage of monthly amortizations, on the ground of petitioners’ failure to develop the subdivision, constitutes a justifiable exercise of their rights under P.D. 957.

Whether the appropriate remedy in this controversy should be specific performance (to enforce the contract to sell) rather than simply an ejectment remedy.
Whether the court’s intervention in a matter predominantly involving regulatory issues interferes with the HLURB’s exclusive mandate.