Case Digest (G.R. No. 84811)
Facts:
Solid Homes, Inc. v. Teresita Payawal, G.R. No. 84811, August 29, 1989, Supreme Court First Division, Cruz, J., writing for the Court. The respondents below were Teresita Payawal (plaintiff/buyer) and the Court of Appeals (which affirmed the trial court); the petitioner was Solid Homes, Inc. (defendant/developer).On June 9, 1975, Solid Homes sold a subdivision lot in Marikina to Payawal for P28,080.00. By September 10, 1981, Payawal alleged she had paid P38,949.87 in monthly installments and interest. Although a deed of sale was executed, Solid Homes failed to deliver the certificate of title; Payawal later learned the property had been mortgaged in bad faith to a financing company. On August 31, 1982, Payawal filed a complaint in the Regional Trial Court (RTC), Quezon City (Civil Case No. Q-36119), seeking delivery of title or, alternatively, refund of all payments plus interest, and claiming moral and exemplary damages, attorney’s fees, and costs.
Solid Homes moved to dismiss for lack of jurisdiction, invoking Presidential Decree No. 957 (PD No. 957), but the RTC denied the motion and proceeded to trial. The RTC rendered judgment for Payawal ordering delivery of title or, in default, refund of P38,949.87 plus interest from 1975 until payment; it also awarded P5,000.00 moral damages, P5,000.00 exemplary damages, P10,000.00 attorney’s fees, and costs.
Solid Homes appealed to the Court of Appeals, which affirmed the RTC. The Court of Appeals relied on Section 41 of PD No. 957 — that remedies under the Decree are “in addition to” other remedies under existing law — to sustain the RTC’s jurisdiction, and it rejected the contrary opinion of the Sec...(Subscriber-Only)
Issues:
- Did the Regional Trial Court have jurisdiction to hear and decide Payawal’s complaint against Solid Homes?
- If jurisdiction lies with the administrative body, does PD No. 1344 (as implementing PD No. 957) vest exclusive jurisdiction in the National Housing Authority (now the Housing and Land Use Regulatory Board) to entertain buyer claims, including claims fo...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)