G.R. No. 233767 - Heirs of Elliot vs. Corcuera

Petitioner Romulo R. Peralta entered into a Contract to Sell on April 22, 1997, with respondent Concepts and Systems Development Inc. (CSDI), the developer and owner of the Elysium condominium project in Parañaque City.
The contract involved the purchase of a condominium unit (Unit 10, Block 3, Phase II) under a Deferred Cash Payment Scheme, with agreed payment installments and a total purchase price of ₱5,000,000.
The subject condominium project had been developed in phases, each issued with its respective Certificate of Registration and “License to Sell.”

50% Downpayment of ₱2,500,000. on April 22, 1997
50% Balance split into two installments: ₱1,250,000 on October 23, 1997 and ₱1,250,000 on April 23, 1998

Despite the delivery and acceptance of the unit in November 1997, petitioner failed to complete payment in full as required under the contract.

On September 16, 1999, CSDI filed a complaint before the Housing and Land Use Regulatory Board (HLURB) for collection/specific performance against petitioner for the unpaid amount.
HLURB Case No. REM-091699-10646 resulted in a decision on October 14, 2000, ordering petitioner to:

Pay ₱3,022,000.00 plus interest and penalties
Alternatively, accept rescission of the contract with forfeiture of payments made to date
Surrender possession of the condominium unit

A writ of execution was issued on December 12, 2005, further enforcing the HLURB decision, including garnishment of petitioner’s bank deposit.

Simultaneously, petitioner and other unit owners initiated HLURB Case No. REM-051500-10995 against CSDI seeking:

On October 29, 2002, HLURB Arbiter San Vicente rendered a decision in this related case against CSDI, with orders affecting project development, management, and the collection/return of fees.

On May 7, 2007, petitioner filed a Complaint for Injunction and Damages (Civil Case No. 07-0141) in the RTC, Branch 258, Parañaque City.
The petition sought temporary and permanent injunctions to restrain CSDI from:

Cancelling the Contract to Sell
Foreclosing the condominium unit and garnishing petitioner’s bank deposits
Claiming damages for alleged hospitalization and imposing additional moral and exemplary damages

The RTC dismissed the complaint on the grounds of lack of jurisdiction and forum shopping.
The Court of Appeals affirmed the dismissal on May 29, 2008, noting that the subject matter was already within the exclusive purview of the HLURB.

Petitioner’s petition raised the issue of whether the RTC and, by extension, the Court of Appeals had jurisdiction to enjoin the execution of the HLURB’s decision, particularly when the HLURB decision had become final and executory.
The petitioner’s failure to disclose concurrent proceedings (forum shopping) and his attempt to litigate the same issues already decided by the HLURB led to the dismissal and subsequent affirmations by higher courts.

Whether the Regional Trial Court had the authority to grant injunctive relief over matters already determined by the Housing and Land Use Regulatory Board.
Whether the HLURB’s exclusive jurisdiction over subdivision and condominium disputes precludes regular courts from intervening.

Whether petitioner’s simultaneous filing of cases in different forums (HLURB and RTC) constituted forum shopping, leading to dismissal.
The impact of non-disclosure of concurrent administrative actions on the merits of the pleadings.

Whether a final and executory decision rendered by the HLURB can be subject to injunction by the regular courts.
Whether petitioner's attempt to enjoin the enforcement of the writ of execution violates the principle of finality of quasi-judicial decisions.