Case Summary (G.R. No. 184482)
Factual Background
On March 3, 1994, Bethel Realty sold a parcel of land in Taytay, Rizal to spouses Nemesio and Marjorie Visaya. After full payment was made on March 24, 1997, a Deed of Absolute Sale was executed; however, Bethel Realty failed to deliver the Transfer Certificate of Title. Marjorie Visaya subsequently sought assistance from the Housing and Land Use Regulatory Board (HLURB).
Proceedings with HLURB
The HLURB treated Marjorie's communication as a verified complaint, which led to a summons issued to the petitioner on November 16, 1999. By its default ruling on December 23, 1999, HLURB decided in favor of the Visayas on September 8, 2000, directing Bethel Realty to deliver the title or refund their payment with interest and damages.
Implementation of HLURB Decision
The sheriff's attempts to execute the HLURB decision were obstructed, as he could not locate the petitioner. Bethel Realty's liability for not delivering the title was clear, resulting in monetary penalties and an administrative fine for violation of pertinent land use laws.
Proceedings with the Court of Appeals
Bethel Realty filed a Petition for Certiorari with Injunction on October 29, 2003. However, it was dismissed by the Court of Appeals due to non-compliance with procedural requirements. The petitioner later re-filed the petition in March 2004, but again faced procedural setbacks for not providing correctly certified documents. After long delays, the Court of Appeals initially issued a decision favorable to Bethel Realty on December 21, 2007, annulling the HLURB decision.
Court of Appeals Amended Decision
Respondents filed for reconsideration, which led to an Amended Decision on May 26, 2008, reinstating the HLURB ruling based on procedural deficiencies in the petition filed by Bethel Realty, particularly the failure to indicate the dates of receipt of the HLURB decision.
Issue Before the Supreme Court
The main issue presented to the Supreme Court was whether the Court of Appeals properly applied provisions regarding material dates per Rule 65 and Rule 46 of the Rules of Civil Procedure, which led to the denial of Bethel Realty's petition.
Supreme Court Ruling
The Supreme Court affirmed the findings of the Court of Appeals, outlining that administrative remedies available to
...continue readingCase Syllabus (G.R. No. 184482)
Background of the Case
- The case involves a Petition for Review on Certiorari filed by Bethel Realty and Development Corporation against the Housing and Land Use Regulatory Board (HLURB) and private respondents, spouses Marjorie and Nemesio Visaya.
- The petition challenges two issuances of the Court of Appeals: (a) an Amended Decision dated 26 May 2008 that denied the Petition for Certiorari, Annulment, Injunction, and (b) a Resolution dated 16 September 2008 that denied the petitioner’s Motion for Reconsideration.
- The Amended Decision reinstated the HLURB's Decision dated 8 September 2000, which ordered the petitioner to deliver the Transfer Certificate of Title for the subdivision lot sold to the respondents.
Factual Antecedents
- On 3 March 1994, Bethel Realty sold a parcel of land in Taytay, Rizal, to spouses Visaya.
- The respondents fulfilled their payment obligations by 24 March 1997 and executed a Deed of Absolute Sale.
- Despite several demands, Bethel Realty failed to deliver the Transfer Certificate of Title to the respondents.
- Marjorie Visaya sought assistance from HLURB, leading to the filing of a verified complaint against Bethel Realty.
Proceedings with the HLURB
- HLURB initiated proceedings after receiving Marjorie’s complaint.
- Petitioner Bethel Realty was declared in default for not responding to the complaint and did not file any answer.
- On 8 September 2000, HLURB ruled in favor of the resp