Case Summary (G.R. No. 187978)
Facts of the Case
On April 22, 1997, petitioner and CSDI entered into a Contract to Sell for Unit 10, Block 3, of The Elysium Project for the total price of PHP 5 million, divided into a 50% down payment and the remaining 50% due in two installments. Despite possession and enjoyment of the unit, Peralta failed to pay the remaining balance due on the established timeline.
In response, CSDI filed a complaint against Peralta for collection and specific performance before the Housing and Land Use Regulatory Board (HLURB) on September 16, 1999. Concurrently, Peralta initiated a separate complaint against CSDI for cancellation of the project’s registration and other claims involving the developer.
Tribunals Involved
Several key decisions were rendered by the HLURB in both cases, one dated October 14, 2000, which ruled against Peralta, ordering him to pay CSDI or face forfeiture of his payments. Peralta’s appeal against this decision was dismissed, solidifying CSDI’s claims. Conversely, the HLURB ruled in favor of Peralta in another case, directing CSDI to undertake necessary actions regarding the project's completion and operations.
Execution of Judgment
Subsequently, HLURB issued a Writ of Execution for the October 2000 decision, leading to the garnishment of Peralta's bank deposit. Peralta's repeated motions to quash the writ were denied, resulting in an order for his ejection from the condominium unit.
Actions Before RTC
In light of these developments, Peralta filed a complaint for injunction and damages against CSDI at the Regional Trial Court (RTC) of Parañaque, which was dismissed for lack of jurisdiction and forum shopping. The RTC held that the subject matter fell under HLURB’s jurisdiction as it stemmed from the execution of its prior decision and that Peralta had omitted relevant prior actions from his filings, constituting forum shopping.
Court of Appeals Decision
Peralta appealed to the Court of Appeals, which affirmed the RTC’s dismissal, reiterating the exclusive jurisdiction of HLURB under the relevant laws—specifically Presidential Decree Nos. 957 and 1344. The appellate court emphasized that despite the issues raised by Peralta regarding damages, they were interconnected with the HLURB’s execution ruling.
Supreme Court Ruling
Petitioner escalated the matter to the Supreme Court, which also upheld the lower courts’ decisions. The Court reaffirmed HLURB’s exclusive jurisdiction over real estate disputes involving developer obligations and buyer claims. It concluded that Peralta’s complaint was essentially a means to enjoin the exe
...continue readingCase Syllabus (G.R. No. 187978)
Case Overview
- The case is a Petition for Review under Rule 45 of the Rules of Court.
- Petitioner: Romulo R. Peralta.
- Respondents: Hon. Raul E. de Leon, Arbiter Dunstan San Vicente, Lucas Eloso Eje, and Concepts and System Development Inc. (CSDI).
- The case primarily revolves around the dismissal of a complaint for injunction and damages filed by the petitioner against CSDI.
Background Facts
- CSDI is the developer of a condominium project called the Elysium located in ParaAque City.
- On April 22, 1997, petitioner entered into a Contract to Sell with CSDI for a condominium unit for a total price of P5 Million, with a deferred cash payment scheme.
- The subject condominium unit was completed in 1996, and a Condominium Certificate of Title was issued.
- Petitioner failed to pay the full amount due, leading CSDI to file a complaint for collection against him with the Housing and Land Use Regulatory Board (HLURB).
- Petitioner subsequently filed his own complaint against CSDI before the HLURB.
HLURB Proceedings
- CSDI's complaint led to a decision by HLURB Arbiter San Vicente on October 14, 2000, ordering Peralta to pay P3,022,000 plus interest or face rescission of the contract and forfeiture of payments.
- Petitioner’s appeal to the Office of the President was dismissed, and the decision became final and executory.
- In a separate HLURB case filed by Peralta ag