Title
Calara vs. Francisco
Case
G.R. No. 156439
Decision Date
Sep 29, 2010
Subdivision buyers dispute developer's compliance with P.D. 957; HLURB holds exclusive jurisdiction, not regular courts, over such cases.
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Case Digest (G.R. No. 156439)

Facts:

  1. Ownership and Subdivision Development

    • Petitioners, Clemencia Calara and her children, owned the Lophcal (Calara) Subdivision in Brgy. Anos, Los Baños, Laguna.
    • Respondents, Teresita and Jesus Francisco, were among the buyers of a lot in the subdivision.
  2. Initial Complaint and Jurisdictional Dispute

    • In 1982, respondents and other buyers filed a complaint with the Human Settlement Regulatory Commission (HSRC, now HLURB) against petitioner Clemencia Calara for violations of P.D. 957 (Subdivision and Condominium Buyers' Protective Decree).
    • The complaint cited issues such as the absence of a drainage system, unfinished roads, and abandoned electrical facilities.
    • Petitioners, in response, claimed the subdivision was exempt from P.D. 957 and filed an unlawful detainer case against respondents in the Municipal Trial Court (MTC) of Los Baños, Laguna.
  3. Unlawful Detainer Case

    • Petitioners alleged that respondents agreed to buy Lot 23 of the subdivision in 1976, made an advance payment, and constructed a house on the lot. However, respondents refused to execute a contract to sell or make further payments.
    • Respondents countered that they stopped payments due to petitioners' failure to develop the subdivision, as mandated by P.D. 957.
  4. HSRC/HLURB Decision

    • In 1985, the HSRC ruled in favor of the buyers, finding petitioner Clemencia Calara liable for violating P.D. 957. The HSRC ordered her to cease selling lots until she secured the necessary licenses and to develop the subdivision within four months.
  5. MTC and RTC Decisions

    • The MTC ruled in favor of petitioners, ordering respondents to vacate the lot and pay damages. The RTC affirmed this decision.
    • Respondents appealed to the Court of Appeals (CA), which reversed the lower courts' decisions, holding that the HLURB had exclusive jurisdiction over the case.

Issue:

  1. Jurisdiction of HLURB vs. Regular Courts

    • Whether the HLURB has exclusive jurisdiction over disputes involving the rights and obligations of subdivision buyers and developers under P.D. 957.
  2. Existence of a Perfected Contract to Sell

    • Whether a contract to sell was perfected between petitioners and respondents, and whether respondents had the right to stop payments due to petitioners' failure to develop the subdivision.
  3. Procedural Lapses by Respondents

    • Whether respondents' procedural lapses before the MTC, RTC, and CA barred them from pursuing their appeal.
  4. Jurisdiction of MTC over Unlawful Detainer

    • Whether the MTC had jurisdiction over the unlawful detainer case despite the involvement of issues regulated by P.D. 957.

Ruling:

The Supreme Court denied the petition, affirming the Court of Appeals' decision. The HLURB, not the regular courts, has exclusive jurisdiction over disputes involving the rights and obligations of subdivision buyers and developers under P.D. 957. The Court held that the case was not a simple unlawful detainer case but involved issues of compliance with P.D. 957, which fall under the HLURB's jurisdiction.

Ratio:

  1. Exclusive Jurisdiction of HLURB

    • Under P.D. 957 and E.O. 90, the HLURB has exclusive jurisdiction over cases involving the sale of subdivision lots and the enforcement of buyers' rights. The Court emphasized that when an administrative agency is granted quasi-judicial functions, all related controversies fall within its jurisdiction to ensure uniformity and expertise in resolving such disputes.
  2. Nature of the Dispute

    • The case involved more than just unlawful detainer. It centered on respondents' right to stop payments due to petitioners' failure to develop the subdivision, as mandated by P.D. 957. This issue is within the HLURB's exclusive jurisdiction.
  3. Perfected Contract to Sell

    • The Court found that a contract to sell was perfected between the parties, as evidenced by the agreed price, terms of payment, and respondents' construction of a house on the lot. Respondents' refusal to execute a written contract did not negate the existence of a valid oral agreement.
  4. Procedural Lapses

    • The Court ruled that respondents' procedural lapses did not bar their appeal. The MTC and RTC had already addressed the merits of the case, and the CA correctly focused on the jurisdictional issue.
  5. HLURB as the Proper Forum

    • The HLURB is the appropriate forum to resolve all issues related to the subdivision's development, respondents' right to stop payments, and petitioners' claims for specific performance. The Court emphasized that split jurisdiction is not favored, and the HLURB's expertise in real estate regulation makes it the best forum for such disputes.

Conclusion:

The Supreme Court upheld the CA's decision, ruling that the HLURB has exclusive jurisdiction over the case. The petition was denied for lack of merit, and the case was remanded to the HLURB for proper resolution.


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