Case Summary (G.R. No. 102193-97)
Factual Background and Contracts
The petitioners entered into separate Contracts to Sell with the Jarenos, who were the owners and developers of the aforementioned subdivision. These contracts outlined the sale of specific lots in exchange for payment of the purchase price, whereby the Jarenos agreed to execute deeds of transfer upon full payment. However, the Jarenos sold these lots to Ruben Habacon, which led to the petitioners filing a complaint for annulment of these sales and reinstatement of their titles, among other requests.
Jurisdictional Dispute and Initial Court Rulings
The initial proceedings were initiated in the Regional Trial Court (RTC) of Calamba. The trial court, however, ruled that it lacked jurisdiction over the petitions because the appropriate authority to resolve these complaints was the Housing and Land Use Regulatory Board (HLRB), in accordance with the provisions of P.D. No. 957 and subsequent amendments. The petitioners contended that the RTC did possess jurisdiction given the specific circumstances of their cases, particularly that their claims involved the annulment of titles held by a third party.
Trial Court's Dismissal Orders
On September 4, 1991, the RTC dismissed the petitions for lack of jurisdiction, reinforcing its position on the exclusive jurisdiction of the HLRB to resolve disputes tied to unsound real estate business practices. The trial court subsequently denied the petitioners’ motion for reconsideration on September 20, 1991, reaffirming that even though Habacon was not the developer, the Jarenos, as the original developers, engaged in questionable business practices that justified the HLRB’s jurisdiction.
Petition for Certiorari and Arguments
The petitioners filed a special civil action for certiorari seeking to annul the orders of dismissal, claiming the RTC had jurisdiction to hear their cases. Critically, the petitioners were past the reglementary period for filing an appeal, and they did not provide justification for this delay. They insisted that their action was appropriate due to the alleged grave abuse of discretion by the trial court, asserting that they had no recourse for the relief sought in a timely manner.
Jurisdictional Principles and the Court's Reasoning
In its analysis, the court stated that generally, an order dismissing a case, whether correctly or incorrectly decided, is subject to appeal and not certiorari. The justices pointed out that remedies of appeal and certiorari are mutually exclusive unless specific exceptional circumstances exist, which the petitioner
...continue readingCase Syllabus (G.R. No. 102193-97)
Case Overview
- This case is a special civil action for certiorari filed by the petitioners against the respondent Judge Odilon I. Bautista of the Regional Trial Court, who dismissed the petitioners' complaints on the grounds of lack of jurisdiction.
- The dismissal was based on the assertion that jurisdiction belonged to the Housing and Land Use Regulatory Board (HLRB) rather than the Regional Trial Court (RTC).
- The petitioners contest the trial court's jurisdictional ruling, seeking to have the dismissals annulled.
Parties Involved
- Petitioners:
- Ms. Emily Yu Fajardo
- Spouses Salvador and Engracia Gianan
- Spouses Rene and Beverly Rodelas
- Spouses Julian and Teresita Cuizon
- Ms. Teresita Rivera and Ricardo Villanueva
- Respondents:
- Hon. Odilon I. Bautista (Presiding Judge, RTC Branch 37, Calamba, Laguna)
- Spouses Isabelo and Purita Jareno (Owners and developers of Calamba Central Compound)
- Ruben Habacon (Purchased lots from Jarenos)
- Cesar S. Reyes (Register of Deeds, Calamba, Laguna)
Factual Background
- The Jarenos, as developers, entered into separate Contracts to Sell with the petitioners for various lots in the Calamba Central Compound subdivision.
- The contracts stipulated that upon full payment, the corresponding deeds would be executed in favor of the petitioners.
- In 1986, th