Case Digest (G.R. No. 187769) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In San Miguel Properties, Inc. v. Sec. Perez, et al., G.R. No. 166836, decided on September 4, 2013 under the 1987 Constitution, San Miguel Properties, Inc. (SMPI), a domestic real estate developer, purchased in 1992, 1993, and April 1993 a total of 130 residential lots from B.F. Homes, Inc. through three deeds of sale. While titles covering lots under the first two deeds were delivered, BF Homes refused to turn over the Transfer Certificates of Title (TCTs) for 20 of the 41 parcels covered by the April 1993 sale, collectively worth ₱39,122,627.00, alleging that its receiver, Atty. Florencio Orendain, had lost authority when replaced by another SEC-appointed receiver in May 1989. On August 15, 2000, SMPI filed a criminal complaint with the Office of the City Prosecutor of Las Piñas (OCP Las Piñas) accusing BF Homes’ directors and officers of violating Section 25 of Presidential Decree No. 957 (PD 957) for non-delivery of fully paid titles. Simultaneously, SMPI instituted an admi... Case Digest (G.R. No. 187769) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Transaction and Non-delivery of Titles
- San Miguel Properties, Inc. (SMPI) purchased 130 residential lots from BF Homes, Inc. in 1992–1993 for ₱106,248,000; full payment of ₱39,122,627 made for 41 lots under the third deed.
- BF Homes delivered titles for lots under first two deeds but withheld 20 Transfer Certificates of Title (TCTs) covering 15,565 sqm under the third deed, alleging that its receiver’s authority had lapsed.
- Parallel Proceedings
- On August 15, 2000, SMPI filed a criminal complaint in the Las Piñas City Prosecutor’s Office for violation of Section 25 PD 957 (non-delivery of titles).
- Simultaneously, SMPI instituted a specific-performance case in the HLURB to compel delivery of the 20 TCTs.
- Procedural History
- City Prosecutor dismissed the criminal complaint on prejudicial-question grounds, deferring to HLURB/SEC issues. DOJ Secretary affirmed in October 2001, citing need for HLURB determination of transaction validity before criminal prosecution. CA denied SMPI’s certiorari petition in February 2004.
- HLURB proceedings were suspended pending SEC resolution on Atty. Orendain’s authority; Office of the President reversed suspension; CA later remanded to HLURB under primary-jurisdiction doctrine. SMPI’s subsequent SC appeal ensued.
Issues:
- Prejudicial Question
- Whether the pending HLURB specific-performance case constitutes a prejudicial question warranting suspension of the criminal prosecution under PD 957.
- Primary Jurisdiction
- Whether the doctrine of primary jurisdiction mandates deferral to the HLURB’s expertise before proceeding with the criminal case.
- Other Contentions
- Whether the malum-prohibitum nature of PD 957 violations or the identity of the party raising prejudicial question alters suspension.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)