Case Digest (G.R. No. 164789) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Christian General Assembly, Inc. v. Spouses Ignacio (G.R. No. 164789, August 27, 2009), Christian General Assembly, Inc. (CGA) contracted on April 30, 1998 with Spouses Avelino C. Ignacio and Priscilla T. Ignacio for the purchase of a 791-sqm subdivision lot in Villa Priscilla Subdivision, Barangay Cutcut, Pulilan, Bulacan, at a total price of ₱2,373,000.00, payable by a down payment and monthly amortizations over three years. On August 5, 2000, the parties amended the contract, extending payment to five years at an increased consideration of ₱2,706,600. CGA faithfully paid installments until its administrative pastor discovered that the lot formed part of consolidated Lots 2-F and 2-G under Presidential Decree No. 27’s Operation Land Transfer, subject to a retention order granted to the original owner under Republic Act No. 6657 on October 2, 1997—a decision affirmed on appeal by the Department of Agrarian Reform, the Office of the President, the Court of Appeals, and ultima Case Digest (G.R. No. 164789) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract to Sell and Parties
- On April 30, 1998, Christian General Assembly, Inc. (CGA) entered into a Contract to Sell with Spouses Avelino C. Ignacio and Priscilla T. Ignacio for Lot 1, Block 4 of Villa Priscilla Subdivision, Barangay Cutcut, Pulilan, Bulacan.
- The agreed price was ₱2,373,000.00, payable by down payment of ₱1,186,500.00 and three-year monthly installments of ₱46,593.85 (24% p.a. interest), starting June 1998.
- Amendment and Payment Performance
- On August 5, 2000, the parties amended the contract: payment term extended to five years, total consideration increased to ₱2,706,600.00, with monthly installments of ₱37,615.00 (24% p.a. interest), starting September 2000.
- CGA made all monthly payments until discovering title defects.
- Title Defects and Underlying Agrarian Litigation
- The subject lot formed part of consolidated Lots 2-F and 2-G (TCT No. 240878) originally awarded under PD No. 27 to tenant-beneficiaries Adriano and Sison.
- Purificacion S. Imperial’s retention of five hectares under RA 6657 was granted by DAR on October 2, 1997, affirmed by the Office of the President and this Court (G.R. No. 165650, Jan. 19, 2005).
- Proceedings Below
- On April 30, 2002, CGA filed in RTC Malolos Branch 14 a complaint for rescission (Art. 1381, Civil Code), restitution of payments, and damages, alleging respondents’ fraudulent concealment of litigation and title defects.
- Respondents moved to dismiss for lack of jurisdiction, invoking HLURB’s exclusive jurisdiction under PD No. 957 and PD No. 1344. RTC denied the motion (Oct. 15, 2002); CA granted respondents’ petition and dismissed the complaint (Oct. 20, 2003); CA denied reconsideration (July 27, 2004).
Issues:
- Jurisdiction
- Does an action to rescind a contract to sell a subdivision lot and claim refund and damages fall under the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB)?
- Or is such an action cognizable by the regular courts?
- Nature of the Cause of Action
- Whether CGA’s action is for rescission under Article 1381 or for breach of contract under Article 1191 (specific performance).
- Whether PD No. 957 and PD No. 1344 limit HLURB’s jurisdiction to actions for specific performance or also cover rescission and refund claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)