Case Digest (G.R. No. 146031)
Facts:
The case involves Delta Development & Management Services, Inc. (hereinafter referred to as petitioner), represented by its officer Ricardo S. De Leon, Sr., versus the Housing and Land Use Regulatory Board (HLURB) as the respondent. The controversy arose from a series of complaints filed against the petitioner concerning its real estate project known as Delta Homes, located in Aniban, Bacoor, Cavite. On July 13, 1999, a complaint was lodged by Elizabeth Nicolas, a buyer from Delta Homes, against the petitioner and Luzon Development Bank before the HLURB, alleging violations of provisions found in Presidential Decree No. 957 and Batas Pambansa Blg. 220. Subsequently, several other lot buyers filed similar complaints against the petitioner.
On April 18, 2000, Arbiter Raymundo A. Foronda rendered a decision in HLURB Case No. RIV-071399-1083, which required the petitioner to pay damages and impose sanctions against it. This initial ruling triggered further scrutiny, and by May
Case Digest (G.R. No. 146031)
Facts:
- Parties and Parties’ Background
- Delta Development & Management Services, Inc. (DELTA), a domestic corporation engaged in real estate development of Delta Homes in Aniban, Bacoor, Cavite, is the petitioner.
- The Housing and Land Use Regulatory Board (HLURB), the government agency overseeing housing and land development, is the respondent.
- Initiation of Complaints Against Petitioner
- On 13 July 1999, Elizabeth Nicolas, one of the lot buyers at Delta Homes, filed a complaint before the HLURB (docketed as HLURB Case No. RIV-071399-1083).
- The complaint alleged that DELTA violated provisions of Presidential Decree No. 957 and Batas Pambansa Blg. 220.
- Subsequently, six additional complaints were lodged by different lot buyers against DELTA.
- HLURB Proceedings and Decision
- On 18 April 2000, Arbiter Raymundo A. Foronda rendered a decision in HLURB Case No. RIV-071399-1083.
- The dispositive portion of the decision ordered:
- Payment by the complainant of P191,613.85 representing the balance on the maximum selling price of P375,000.00.
- Delivery of the title by DELTA, free from liens and encumbrances, upon full payment.
- Award of P50,000.00 each as moral and exemplary damages to the complainant.
- Payment of P10,000.00 as costs of suit and a similar administrative fine to the HLURB.
- Allegations of Procedural Irregularity
- In May 2000, spouses Luis and Letty Sierra visited the HLURB office and were informed by an employee, Jun Labapi, that he had prepared complaints and documents against DELTA on behalf of the lot buyers.
- Labapi also purportedly admitted to having prepared answers in another complaint filed by a different developer, which raised concerns about impartiality.
- Filing of the Petition for Prohibition
- On 11 July 2000, DELTA filed a petition for prohibition before the Court of Appeals.
- The petition sought a preliminary injunction and a writ of prohibition to stop the HLURB from further proceeding with the resolution of the buyers’ complaints.
- Petitioner contended that HLURB’s conduct, including the alleged drafting of complaints by its employee, resulted in a process that was tainted with bias and deprived DELTA of due process.
- Court of Appeals Resolutions
- On 25 July 2000, the Court of Appeals issued its first resolution dismissing the petition for prohibition, holding that it violated the doctrine of exhaustion of administrative remedies.
- The court noted the petitioner’s failure to implead the complainants as respondents and to serve copies of the petition on them.
- On 7 November 2000, a second resolution issued by the same court denied the petitioner’s motion for reconsideration.
Issues:
- Whether the Court of Appeals correctly ruled that the petition for prohibition violates the doctrine of exhaustion of administrative remedies.
- The petitioner argued that its petition for prohibition was directed at the HLURB’s ongoing proceedings, not any final resolution, thereby exempting it from the exhaustion requirement.
- The court, however, maintained that the petitioner still had available remedies within the HLURB system.
- Whether the respondent (HLURB) committed grave abuse of discretion amounting to a lack or excess of jurisdiction by allegedly participating in the preparation of complaints against DELTA.
- Petitioner contended that HLURB’s involvement through its employee, Jun Labapi, undermined the impartiality of its proceedings and violated DELTA’s right to due process.
- The issue also raised whether such alleged interference warranted a writ of prohibition given the available administrative remedies.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)