Case Summary (G.R. No. 224973)
Facts Surrounding the Transaction
In 1998, Gina Lefebre made a reservation for a residential lot based on the representation that a championship golf course would be developed. Initially reserving a smaller lot, she subsequently upgraded to a larger parcel, leading to a Contract to Sell that required a 30% down payment and monthly amortizations. However, the anticipated golf course was never developed, prompting Lefebre to fall behind on her payments, eventually leading to the cancellation of the contract by the respondent. Lefebre then filed a complaint against the respondent, asserting she had paid a total of P8.1 million.
HLURB Arbiter's Decision
In January 2011, the HLURB Arbiter ruled in favor of A Brown Company, stating that Lefebre's claim of misleading advertisement was raised only after her failure to pay. The Arbiter did, however, acknowledge that Lefebre was entitled to a cash surrender value before cancellation of the contract could take place, thereby emphasizing that the respondent had not fulfilled its duty to develop the promised golf course.
HLURB Board of Commissioners' Ruling
The HLURB Board of Commissioners, in May 2011, reversed the Arbiter’s decision, declaring the cancellation of the Contract to Sell invalid, citing failure to pay the cash surrender value. The Board ruled that an outstanding entitlement to a full refund of the payments made by Lefebre existed, along with additional damages and sanctions against A Brown Company.
Proceedings Before the Court of Appeals
Following the unfavorable ruling of the HLURB BOC, A Brown Company sought judicial remedy through a petition for certiorari. The Court of Appeals initially dismissed it for failure to exhaust administrative remedies but later reinstated the case, ultimately siding with the HLURB Arbiter’s findings. The CA noted that Lefebre’s ongoing non-payment invalidated the reason for rescinding the Contract to Sell, although it recognized her right to cash surrender benefits.
Key Legal Issues
The primary legal issue before the Supreme Court was whether the CA's reinstatement of the HLU Arbiter's Decision was justified despite respondent's procedural missteps in filing for certiorari without appealing to the Office of the President.
Ruling of the Supreme Court
The Supreme Court granted the petition, holding that the respondent's failure to exhaust administrative remedies disallowed the CA
...continue readingCase Syllabus (G.R. No. 224973)
Case Background
- This case originated from a petition for review on certiorari, challenging the Decision dated July 8, 2015, and the Resolution dated May 24, 2016, of the Court of Appeals (CA).
- The CA set aside the HLURB Board of Commissioners (BOC) decision dated May 10, 2011, and reinstated the ruling of the Housing and Land Use (HLU) Arbiter dated January 5, 2011.
- The central issue involved the provisions of Republic Act No. 6552 concerning the prior payment of cash surrender value before the cancellation of the contract to sell.
Facts of the Case
- In 1998, petitioner Gina Lefebre made a reservation to buy a residential lot in Xavier Estates, motivated by the promise of a Manresa 18-Hole All Weather Championship Golf Course developed by the respondent, A Brown Company, Inc.
- The initial reservation for a 576-square meter lot was upgraded to a 1,107-square meter lot, priced at P5,313,600.00, including a down payment of P1,594,080.00 (inclusive of a P10,000 reservation fee).
- The golf course was never developed, leading to cancellation of the Contract to Sell due to Lefebre's alleged failure to pay the remaining balance, which she offered to settle within six months.
- Lefebre filed a complaint against the respondent, claiming she had paid a total of P8.1 million, with only P1,345,722.18 remaining unpaid.
Respondent's Position
- The respondent contended that Lefebre became remiss in her payment obligations as early as 2001, leading to cancellation of the contract.
- They argued