Case Digest (G.R. No. 154877)
Facts:
Jin‑Jin Delos Santos v. Spouses Reynato D. Sarmiento and Leni C. Sarmiento and IA‑JAN Sarmiento Realty, Inc., G.R. No. 154877, March 27, 2007, Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.Petitioner Jin‑Jin Delos Santos entered into a Contract to Buy and Sell dated March 17, 1995 with Spouses Reynato D. Sarmiento and Leni C. Sarmiento for an 82‑square meter lot in IA‑JAN Homes (TCT No. 95442) at a purchase price of P824,000. Santos paid P300,000 down and agreed to pay the balance in installments. On April 19, 1997 the parties executed a Cancellation of Contract providing that the Spouses would refund Santos P584,355.10 and Santos would surrender possession of the lot.
When the Spouses failed to effect the refund, Santos demanded payment (July 14, 1999) and later filed a complaint with the Housing and Land Use Regulatory Board (HLURB) Expanded NCR Field Office to enforce the cancellation and seek refund with interest (docketed REM‑102299‑10723). The HLURB proceeding generated confusion over parties: some HLURB orders named IA‑JAN Sarmiento Realty, Inc. (IJSRI) as respondent; IJSRI itself filed a separate HLURB complaint for specific performance against Santos (docketed REM‑102299‑10732), alleging Santos paid only 13 installments and owed a balance. Santos admitted payments to IJSRI but claimed additional payments and relied on the cancellation to extinguish obligations.
Arbiters issued conflicting orders on consolidation. Arbiter San Vicente initially granted consolidation, later directed REM‑10732 to be heard separately, yet Arbiter Melchor treated the cases as consolidated and on February 26, 2001 rendered judgment ordering IJSRI to pay Santos P584,355.10 with 18% interest plus P50,000 damages and attorneys’ fees; Regional Director Octavio Canta approved. IJSRI filed a Petition for Review with the HLURB Board of Commissioners but Arbiter Melchor dismissed it on February 26, 2002 for failure to attach an appeal bond, and Director Canta approved.
IJSRI filed a petition for certiorari and mandamus with the Court of Appeals (CA). In an August 20, 2002 Decision the CA found grave abuse of discretion by Arbiter Melchor and the Regional Director, vacated the HLURB Decision and Order, and directed the HLURB to dispose of REM‑102299‑10732 separately in accordance with Arbiter San Vicente’s June 7, 2000 order. Santos did not move for reconsideration in the CA but instead filed this Rule 45 petition for review on certiorari assailing the CA decision on three grounds: (1) CA erred in finding grave abuse in consolidation and consolidated decision where issues and parties were substantially the same; (2) CA disregarded the corporate veil d...(Subscriber-Only)
Issues:
- Did the HLURB have jurisdiction over REM‑102299‑10723 and REM‑102299‑10732?
- If HLURB had jurisdiction, did the Court of Appeals commit grave abuse of discretion in setting aside Arbiter Melchor’s consolidated decision and remanding the cases for separate disposition?
- If HLURB had jurisdiction, did the Court of Appeals err in finding grave abuse in Arbiter Melchor’s dismissal of IJSRI’s petition fo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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