Case Summary (G.R. No. 92461)
Jurisdictional Issue
The primary legal question under consideration pertains to the proper jurisdiction for resolving disputes related to real estate transactions, particularly whether the case falls under the jurisdiction of regular courts, as per Batas Pambansa Bilang 129, or under the jurisdiction of the Housing and Land Use Regulatory Board (HLURB), which succeeded the National Housing Authority (NHA) under Presidential Decree No. 957.
Facts of the Case
On May 23, 1988, the petitioner filed a complaint in the Regional Trial Court of Manila to collect the unpaid balance due under a promissory note executed by the respondents in connection with the purchase of a lot in the subdivision. The respondents refused to fulfill their payment obligations, alleging that the petitioner had abandoned its obligation to develop the subdivision. Subsequently, the Antipolo Hills Homeowners Associations, Inc., which included the respondents, lodged their complaints against the petitioner with the HLURB for non-development.
HLURB Findings
The HLURB issued an order allowing the homeowner members to suspend their monthly amortization payments and directed the petitioner to fulfill its development obligations. The HLURB subsequently issued detailed directives regarding the subdivision's infrastructure and service developments, mandating compliance within six months and imposing an administrative fine on the petitioner.
Court Proceedings and Rulings
The petitioner appealed the HLURB's decision, which was upheld by the HLURB, reinforcing the earlier findings of the Housing and Land Use Arbiter. Concurrently, a civil case initiated by the petitioner against the respondents for collection was initially decided favorably for the petitioner on September 26, 1988. However, the respondents successfully appealed this ruling to the Court of Appeals, which determined that the regional trial court lacked jurisdiction over the matter.
Judicial Authority and Regulatory Jurisdiction
Presidential Decree No. 1344 grants the NHA exclusive jurisdiction over certain matters concerning real estate, including cases involving buyers' claims against developers. Citing prior decisions, including Estate Developers and Investors Corporati
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Case Background
- The case revolves around the issue of jurisdiction regarding a complaint filed by Estate Developers and Investors Corporation (the petitioner) against Rosalie Oropesa and/or Nestor Oropesa (the respondents) for the collection of a balance due on a promissory note.
- The complaint was filed in the Regional Trial Court of Manila on May 23, 1988, seeking to collect the unpaid price of a lot purchased by the respondents in the Antipolo Hills Subdivision.
Respondents' Defense
- The respondents refused to pay the remaining balance due to the petitioner's alleged abandonment of its obligation to develop the subdivision fully.
- This dissatisfaction led the respondents and other buyers to form the Antipolo Hills Homeowners Associations, Inc. to collectively address their grievances against the petitioner.
Actions by the Homeowners Association
- The Association lodged a complaint with the Housing and Land Use Regulatory Board (HLURB) under the jurisdiction granted by Presidential Decree No. 957 for the non-development of the subdivision.
- The Association sought to restrain the petitioner from collecting monthly amortizations and requested permission for respondents to pay these directly to the HLURB.
HLURB's Rulings
- The HLURB issued an order allowing members of the Association to suspen