Title
Fajardo vs. Bautista
Case
G.R. No. 102193-97
Decision Date
May 10, 1994
Petitioners sought annulment of lot sales, specific performance, and damages after developers sold same lots to another buyer. RTC dismissed, citing HLRB jurisdiction; SC upheld, ruling certiorari improper due to lapsed appeal.

Case Digest (G.R. No. 102193-97)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • This is a special civil action for certiorari filed by multiple petitioners seeking to annul two orders of the Regional Trial Court (RTC) of Calamba, Laguna.
    • The orders in question were:
      • The Order dated 4 September 1991 dismissing the petitioners’ complaints for lack of jurisdiction.
      • The Order dated 20 September 1991 denying the petitioners’ motion for reconsideration.
    • The petitioners contest that the RTC has jurisdiction over their complaints, contrary to the trial court’s finding that jurisdiction belongs to the Housing and Land Use Regulatory Board (HLRB).
  • Parties and Transactional Background
    • Petitioners
      • Multiple lot buyers involved in separate individual contracts to sell with private respondents (the Jarenos and Fernando Realty and Development Corporation).
      • Specific contracts include those executed by Spouses Julian and Teresita Cuizon, Teresita Rivera and Ricardo Villanueva, Spouses Rene and Beverly Rodelas, Spouses Salvador and Engracia Gianan, and Emily Yu Fajardo.
    • Respondents
      • Private respondents, Isabelo and Purita Jareno, who are the owners and developers of the Calamba Central Compound Subdivision.
      • Private respondent Fernando Realty and Development Corporation, which entered into a separate contract with petitioner Fajardo.
      • Additional respondent HABACON, who acquired the lots through separate documents known as “Kasulatan ng Bilihan” following the contracts to sell executed with the Jarenos.
  • Details on the Real Estate Transactions
    • Contracts to Sell
      • The petitioners entered into agreements with the Jarenos and Fernando Realty, under which the developers bound themselves to sell specific subdivision lots upon full payment and to execute corresponding deeds of absolute sale.
      • Specific details were cited regarding lot numbers, block numbers, dates of execution, and corresponding titles (e.g., TCT numbers).
    • Subsequent Sale to HABACON
      • On 18 October 1986, the Jarenos sold the same lots to HABACON via documents entitled “Kasulatan ng Bilihan.”
      • On 18 February 1991, HABACON effected the cancellation of the original certificates of title and had new ones issued in his name.
    • Relief Sought by Petitioners
      • Annul the sale (Kasulatan ng Bilihan) executed in favor of HABACON, declaring it as an equitable mortgage.
      • Annul and reverse the cancellation of the original certificates of title, reinstating them.
      • Enforce their contractual rights by obtaining specific performance regarding the deeds of sale and refraining from any unsound business practices by the Jarenos.
      • Claim damages, including actual, exemplary, attorney’s fees, and other costs.
  • Procedural History and Trial Court Rulings
    • Filing of Complaints
      • Separate complaints were filed on 21 June 1991 and docketed under Civil Cases Nos. 1683-91-C, 1684-91-C, 1685-91-C, 1686-91-C, and 1688-91-C in Branch 37 of the RTC of Calamba.
    • Motion to Dismiss
      • HABACON filed a motion to dismiss on 9 August 1991, arguing the petitioners lacked legal capacity because they were not parties to the “Kasulatan ng Bilihan.”
    • RTC’s Orders
      • Order of 12 August 1991 directing the petitioners to show cause why the case should not be dismissed for lack of jurisdiction pursuant to P.D. No. 957 (as amended by P.D. No. 1344), citing the precedent in Solid Homes, Inc. vs. Payawal.
      • Upon receiving the petitioners’ compliance, the RTC eventually dismissed the complaints on 4 September 1991 for lack of jurisdiction.
      • The trial court’s subsequent motion for reconsideration filed by the petitioners was denied on 20 September 1991.
    • Special Civil Action for Certiorari
      • Petitioners filed the current special civil action on 24 October 1991 to annul the dismissed complaints, arguing grave abuse of discretion and a lack of alternative remedial action.
    • Procedural Issues Raised
      • The petition was filed beyond the 15-day period to appeal the dismissed order.
      • Petitioners failed to show valid exceptions to the prohibition on substituting certiorari for an ordinary appeal.

Issues:

  • Jurisdiction
    • Whether the RTC correctly dismissed the petitioners’ complaints on the ground that the subject matter falls under the exclusive jurisdiction of the HLRB as provided in P.D. No. 957 (amended by P.D. No. 1344).
    • Whether Section 19(1) of B.P. Blg. 129, which generally vests jurisdiction in the RTC for cases involving real property, is overridden by the special law (P.D. No. 957 and its amendments).
  • Availability and Appropriateness of Remedies
    • Whether the petitioners’ special civil action for certiorari is a proper remedy despite the existence of an ordinary appeal mechanism.
    • Whether certiorari can substitute for the lost appeal remedy, especially when the petition was filed beyond the reglementary period without showing exceptional circumstances.
  • Application of Precedents
    • Whether the precedent established in Solid Homes, Inc. vs. Payawal is aptly applicable in the present case, given the differing circumstances regarding the transfer of title and the role of HABACON.
    • The proper interpretation of jurisdictional provisions when a case involves unsound real estate business practices alongside claims for specific performance and damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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