Case Summary (G.R. No. 131903)
Background of the Case
The petition for certiorari challenges the September 17, 1997, decision of the Court of Appeals, which dismissed the appeal filed by the petitioners concerning a June 5, 1995, order by the Regional Trial Court of Quezon City. The petitioners sought the annulment of certain documents and the enforcement of their rights concerning a road lot adjacent to their properties.
Facts of the Case
Petitioners claim ownership over several lots adjacent to a road lot known as Lot 369-A-29 (Apollo Street) in Quezon City. This road lot was covered under Transfer Certificate of Title (TCT) No. RT-20895, registered in the name of respondent Pedro del Rosario. Notably, an annotation on the title prohibits del Rosario from closing or disposing of the road lot without prior court approval. Petitioners allege that del Rosario violated this order by selling part of the road lot to co-respondents Conejero and Sonoron without court authorization. Following this, a partition agreement was made, subdividing the lots and regaining titles, subsequently leading to construction activities by Goldkey Development Corporation that blocked access to the petitioners' properties.
Decisions by Lower Courts
The Regional Trial Court dismissed the petitioners' case, stating it lacked jurisdiction, since an administrative ruling by the building official had previously declared the disputed property as a residential lot. The court noted that no appeals were filed related to this ruling or the HLURB's authorization for Goldkey's development project, thereby affirming that jurisdiction rested with the HLURB, not the regular courts. The Court of Appeals upheld this dismissal, reiterating the same points regarding procedural defects and a lack of jurisdiction.
Jurisdictional Issues
The key issue addressed in the appeals focused on the jurisdiction over the case. The HLURB was identified as the regulatory body with exclusive jurisdiction over matters concerning subdivisions and real estate developments, based on pertinent laws that empower it to handle issues of this nature. The appellate court ruled that any redress sought by the petitioners fell under the jurisdiction of the HLURB for specific performance regarding the statutory rights associated with subdivision road lots.
Legal Principles Involved
The ruling underscored the importance of administrative jurisdiction in matters related to the regulation of real estate. The court highlighted the distinction between administrative and judicial jurisdiction, asserting that issues adequately addressed by administrative agencies should not be re-litigated in regular courts.
...continue readingCase Syllabus (G.R. No. 131903)
The Case
- This case involves a petition for certiorari challenging the 17 September 1997 Decision of the Court of Appeals, which dismissed the appeal of the petitioners regarding an earlier order from the Regional Trial Court (RTC) of Quezon City.
- The RTC's order, dated 5 June 1995, dismissed the petitioners' case for lack of jurisdiction, which sought the annulment of documents related to the sale and partition of a road lot.
The Facts
- Petitioners are the registered owners of several lots adjacent to a road lot known as Lot 369-A-29, which connects their properties to the main road, Road 20.
- The road lot is covered by Transfer Certificate of Title (TCT) No. RT-20895, registered in the name of respondent Pedro del Rosario, with a crucial annotation prohibiting its sale or closure without prior court approval.
- Allegations were made that del Rosario sold a portion of this road lot to co-respondents Josefa Conejero and Ignacio Sonoron without obtaining the required court approval.
- Subsequently, a partition agreement altered the original title, resulting in new titles issued to Conejero, Sonoron, and del Rosario.
- The petitioners claimed that the Register of Deeds violated the court order by registering these sales without judicial consent and that Goldkey Development Corporation, who acquired one of the new titles, had obstructed access to their property.
The Ruling of the Trial Court
- The RTC dismissed the petitioners' case due to lack of jurisdiction, emphasizing that a prior decision by the building official established