Title
Manila Bankers Life Insurance Corp. vs. Eddy Ng Kok Wei
Case
G.R. No. 139791
Decision Date
Dec 12, 2003
A Singaporean businessman sued Manila Bankers Life for delayed condominium delivery. Courts ruled in his favor, awarding damages, as the developer’s active participation estopped jurisdiction challenges.

Case Summary (G.R. No. 139791)

Factual Background

Eddy Ng Kok Wei expressed his intention to purchase a condominium unit at Valle Verde Terraces through a Letter of Intent to Manila Bankers Life Insurance Corporation on November 29, 1988. Following this, he paid a reservation fee of P50,000.00 on December 5, 1988. By January 16, 1989, he had paid 90% of the purchase price, totaling P729,830.00, leading to the execution of a Contract to Sell. The contract stipulated that the condominium unit was to be "substantially completed and delivered" within fifteen months from February 8, 1989, with a penalty applied in the event of delays.

Delay in Delivery

As the deadline approached, Eddy Ng returned to the Philippines in April 1990. Petitioner communicated that the condominium unit was substantially complete but indicated delays due to various uncontrollable issues. Although a notice was issued for delivery on May 31, 1990, when Ng returned, the unit was uninhabitable. This situation continued through several visits until he formally demanded damages on November 21, 1990, as no action was taken by petitioner to rectify the issues.

Legal Proceedings

Frustrated, Eddy Ng filed a complaint for specific performance and damages in the Regional Trial Court, Makati City, which was docketed as Civil Case No. 90-3440. Eventually, he accepted the unit and occupied it on April 12, 1991, limiting his claim to damages. On December 18, 1992, the trial court ruled in favor of Ng, awarding him damages due to the unreasonable delay in fulfilling the contractual obligation.

Court of Appeals Decision

The Court of Appeals affirmed the trial court's decision on March 26, 1999. Petitioner’s attempt to challenge the trial court’s jurisdiction, based on the assertion that the National Housing Authority (now the Housing and Land Use Regulatory Board or HLURB) had exclusive jurisdiction over such disputes, was met with several considerations.

Jurisdictional Issues

Petitioner argued against the jurisdiction of the trial court, referencing Section 1(c) of Presidential Decree No. 1344. However, the Supreme Court found that despite any lack of jurisdiction, Manila Bankers Life Insurance Corporation's active participation in the proceedings effectively estopped it from subsequently claiming a lack of jurisdiction. The Court highlighted that a party cannot engage in proceedings and accept the favorable judgment while contesting jurisdiction when the outcome is unfavorable.

Findings of Facts

Regarding the claim of no delay by the petitioner, the Supreme Court reiterated its

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