Case Summary (G.R. No. 171953)
Applicable Law
The decision is grounded within the framework established by the 1987 Philippine Constitution, as well as under the laws governing government-owned and controlled corporations, specifically Presidential Decree No. 757, and the provisions of Presidential Decree No. 1445 pertaining to the Commission on Audit (COA).
Background of the Case
Ernesto Roxas applied for and was awarded commercial lots within the NHA’s development project. Following his application in December 1985, Roxas made a down payment based on the approved price per square meter. Subsequent to a re-survey, his lots’ areas were increased, leading to a dispute regarding the additional costs associated with the increased area. When negotiations failed, Roxas pursued judicial remedies, seeking specific performance and damages through the Regional Trial Court (RTC).
RTC Proceedings and Rulings
The RTC ruled in favor of Roxas, ordering the NHA to execute a contract to sell encompassing the total area at the previously agreed price. The NHA appealed this decision, which was subsequently affirmed by the Court of Appeals (CA). The RTC also granted Roxas a writ of preliminary injunction, and attorney’s fees were awarded as part of the judgment.
Appeal and Motion for Execution
After a series of procedural steps and motions, including Roxas seeking enforcement of the judgment, the RTC issued a writ of execution. The NHA contested this, arguing that any monetary judgment against it required prior review and approval from the COA before execution could occur. The NHA filed a petition for certiorari with the CA, asserting that the RTC had abused its discretion.
CA’s Decision
The CA found no grave abuse of discretion on the part of the RTC and maintained that the writ of execution was valid. It established that the NHA, as a corporation that could sue and be sued, was not immune from complying with the court's judgment. The CA emphasized that Roxas had a legal right to execute the judgment concerning the specific performance but noted the complexities surrounding the attorney’s fees.
Issues Raised
The pivotal issues debated included whether the NHA's submission to litigation constituted a waiver of its sovereign immunity and whether claims for monetary judgments against the NHA must first be adjudicated by the COA rather than being immediately enforceable through execution.
Supreme Court Ruling
The Supreme Court partly granted the petition for review, clarifying the legal framework under which the NHA operates. It ruled that while the NHA could be compelled to comply with the main relief of specific performance without COA approval, any monetary judgment, such as attorney’s fees, mandated prior submission
...continue readingCase Syllabus (G.R. No. 171953)
Case Citation
- 772 Phil. 26; 112 OG No. 26, 4011 (June 27, 2016)
- G.R. No. 171953, October 21, 2015
Parties Involved
- Petitioner: National Housing Authority (NHA)
- Respondent: Ernesto Roxas
Background of the Case
- The NHA, a government-owned and -controlled corporation under Presidential Decree No. 757, is authorized to sue and be sued.
- The case arose from the NHA's challenge to a decision by the Court of Appeals (CA) which dismissed its petition for certiorari against orders from the Regional Trial Court (RTC) regarding a writ of execution in favor of Roxas.
Relevant Facts
- On December 4, 1985, Ernesto Roxas applied for commercial lots within the Dagat-dagatan Development Project, and his application was approved by the NHA.
- The NHA issued an order of payment and a notice of award for the lots, leading Roxas to make a downpayment.
- Subsequent changes in the project resulted in the renumbering and area increase of the lots awarded to Roxas.
- Roxas completed his payment for the lots by December 20, 1991, but sought a reduction in the price for the additional area due to NHA’s unilateral actions.
- After the NHA rejected his appeal, Roxas initiated a lawsuit against the NHA for specific performance and damages.
- The RTC ultimately ruled in favor of Roxas, declaring him the legal awardee of the lots and o