G.R. No. 221932 - Dela Torre vs. Primetown Property Group, Inc.

Petitioner Patricia Cabrieto dela Torre, represented by Benigno T. Cabrieto, Jr., filed a petition for review on certiorari seeking to annul and set aside the Court of Appeals (CA) decision dated April 28, 2015 and the resolution dated November 25, 2015 denying reconsideration.
Respondent Primetown Property Group, Inc. is engaged in real estate holding, owning, and development with projects in Makati and Cebu City.
Respondent faced financial difficulties following the 1997 Asian financial crisis due to peso devaluation, increased interest rates, and limited credit access.

Respondent filed a petition for corporate rehabilitation with prayer for suspension of payments and actions at the Regional Trial Court (RTC) of Makati City, Branch 138, in 2003.
The RTC issued a Stay Order on August 15, 2003, suspending enforcement of all claims and actions against respondent.

On October 15, 2004, petitioner filed a Motion for Leave to Intervene, seeking a judicial order for specific performance commanding respondent to execute a deed of sale covering Unit 3306, Makati Prime Citadel Condominium, alleging full payment of the purchase price.
Respondent opposed, arguing the motion was filed out of time under the Interim Rules of Procedure on Corporate Rehabilitation, which required claims to be filed at least ten (10) days before the initial hearing set on September 24, 2003.

On August 24, 2011, the RTC granted petitioner’s motion for intervention, ruling that the motion was timely filed and that petitioner had convincingly proven full payment. The court ordered respondent to:

Execute a deed of absolute sale covering Unit 3306 in favor of petitioner.
Deliver the Owner’s Duplicate of the Condominium Certificate of Title No. 25161 along with pertinent documents for registration and issuance of a new title.
Immediately transfer possession of the unit to petitioner.

Respondent filed a motion for reconsideration claiming unpaid interest and penalty charges remained and contended the Housing and Land Use Regulatory Board (HLURB), not the RTC, had exclusive jurisdiction over condominium disputes.
The RTC denied the motion for reconsideration on April 16, 2012.

Respondent elevated the case to the CA through a petition for certiorari.
On April 28, 2015, the CA annulled and set aside the RTC's August 24, 2011 order, denying petitioner’s motion for intervention, and concluded:

The Stay Order issued by the rehabilitation court on August 15, 2003 stayed the enforcement of all claims against respondent.
Petitioner’s action to execute a certificate of title is a claim barred by the Stay Order.
The RTC did not have jurisdiction to entertain petitioner’s intervention given HLURB’s exclusive jurisdiction over condominium matters.

Petitioner contended that her claim was not suspended by the Stay Order since she had paid the purchase price as early as July 25, 1996.
She argued that “claims” pertain to pecuniary demands and debts, not a prayer for specific performance to execute a deed of sale.
She relied on Town and Country Enterprises, Inc. v. Hon. Quisumbing, Jr., et al. to support her position.

Whether the RTC erred in allowing petitioner’s intervention and granting the order for respondent to execute a deed of sale despite the Stay Order issued in corporate rehabilitation.
Whether the Stay Order suspends petitioner’s claim for specific performance to execute a deed of sale on the condominium unit.
Whether the RTC had jurisdiction over petitioner’s claim involving a condominium unit or whether exclusive jurisdiction lies with the HLURB.
Whether the CA committed reversible error in annulling the RTC’s order and denying petitioner’s motion to intervene.
Whether petitioner fully paid the purchase price for Unit 3306 as found by the RTC.