G.R. No. 139791 - Manila Bankers Life Insurance Corp. vs. Eddy Ng Kok Wei

Case Digest (G.R. No. 139791)
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Facts:

Parties and Transaction Background

Respondent: Eddy Ng Kok Wei, a Singaporean businessman investing in the Philippines.
Petitioner: Manila Bankers Life Insurance Corporation.
Initial Negotiations and Payments:

On November 29, 1988, respondent sent a Letter of Intent to petitioner expressing his intention to purchase a condominium unit at Valle Verde Terraces.
On December 5, 1988, respondent paid a reservation fee of P50,000.00.
On January 16, 1989, respondent paid 90% of the purchase price—P729,830.00 for the 46-square meter unit valued at P860,922.00.

Contract Formation and Terms

Execution of the Contract to Sell was done by petitioner’s President, Mr. Antonio G. Puyat, in favor of respondent.
Key contractual provisions included:

A delivery clause requiring that the condominium unit “shall substantially be completed and delivered” within fifteen (15) months from February 8, 1989 (i.e. on or before May 8, 1990).
A penalty clause stipulating a charge of 1% of the total amount paid by the respondent if the unit was not substantially completed and delivered on the specified date.

Issues on Delivery and Subsequent Developments

Notice of Substantial Completion:

On April 5, 1990, petitioner, through its Senior Assistant Vice-President, Mr. Mario G. Zavalla, informed respondent of the substantial completion of his unit.
However, due to factors such as coup d’etat attempts, a typhoon, and shortages of steel and cement, the final turnover was reset to May 31, 1990.

Repeated Failures to Deliver a Habitable Unit:

On July 5, 1990, after receiving a notice of delivery dated May 31, 1990, respondent went to the property only to find the unit uninhabitable due to the absence of water and electric facilities.
A subsequent notice directed by petitioner indicated a scheduled move-in date of August 22, 1990, but when respondent returned on October 5, 1990, the unit remained unlivable.

Respondent’s Reaction and Legal Action:

On November 21, 1990, respondent sent a letter demanding payment for the damages sustained due to the delay and defects in the unit.
Petitioner ignored the demand, prompting respondent to file a complaint for specific performance and damages with the Regional Trial Court, Branch 150 in Makati City (Civil Case No. 90-3440).
During the pendency of the case, respondent eventually accepted and occupied the unit on April 12, 1991, thereby limiting his cause of action to his claim for damages.

Judicial Proceedings and Rulings

The Regional Trial Court rendered a Decision on December 18, 1992, finding petitioner liable for damages due to the delay.

Award included:

One percent (1%) of the total amount paid;
P100,000.00 as moral damages;
P50,000.00 as exemplary damages;
P25,000.00 as attorney’s fees; and cost of suit.

The Court of Appeals affirmed the trial court’s decision in its Decision dated March 26, 1999.
A motion for reconsideration filed by petitioner was denied by the Appellate Court on August 5, 1999.

Petition for Review and Jurisdictional Contentions

Petitioner filed a petition for review on certiorari assailing the CA decisions.
Jurisdictional Issue Raised by Petitioner:

Petitioner contended that the trial court had no jurisdiction as Section 1(c) of Presidential Decree No. 1344 (as amended) vests exclusive jurisdiction in the Housing and Land Use Regulatory Board (HLURB) for cases involving specific performance of contractual and statutory obligations by buyers of condominium units.
It was argued that the subject case falls within the exclusive jurisdiction of the HLURB.

Petitioner’s Other Contention:

It was also maintained that petitioner did not incur the delay as alleged, thereby disputing the award of damages.

Court’s Findings on Jurisdiction and Delay

Jurisdiction Issue:

Although the complaint would normally fall under HLURB’s exclusive jurisdiction, petitioner’s active participation in the proceedings (and failure to raise the jurisdictional issue in the trial and appellate courts) estopped petitioner from later contesting the trial court’s jurisdiction.

On Delay:

The court emphasized that whether the petitioner incurred delay and the resultant liability for damages are factual issues.
Factual findings by the trial court, when supported by substantial evidence and affirmed by the Court of Appeals, are not subject to review unless they manifest errors of law or misapprehension of facts.

Issues:

Jurisdiction

Whether the trial court had proper jurisdiction over the case given that the exclusive jurisdiction under Section 1(c) of Presidential Decree No. 1344, as amended, vests such matters in the HLURB.
Whether petitioner’s failure to raise the jurisdictional issue earlier amounts to an estoppel, thus precluding its current challenge on jurisdiction.

Delay in Performance

Whether petitioner indeed incurred unreasonable delay in delivering the condominium unit as stipulated in the contract.
Whether the delay, if proven, justifies the imposition of damages as awarded by the trial court and upheld by the Court of Appeals.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 139791)
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