Case Summary (G.R. No. 109703)
Facts of the Case
Private respondent Lucina C. Sendino entered into a reservation agreement with Realty Exchange Venture, Inc. (REVI) for a 120-square meter lot at Raymondville Subdivision in Sucat, Paranaque, priced at P307,800. Ms. Sendino made an initial reservation fee payment of P1,000.00 on January 15, 1989, and subsequently paid an additional P4,000.00 to complete the reservation fee by January 20, 1989. On July 18, 1989, she paid a full downpayment of P16,600.00. However, REVI advised her to change her co-maker, which led to an agreed extension of one month for compliance. Subsequently, on July 31, 1989, REVI notified Sendino of the cancellation of the contract due to alleged non-compliance with document submission requirements.
Legal Proceedings Initiated
On April 20, 1990, Sendino filed a complaint for Specific Performance against REVI with the Office of Appeals, Adjudication, and Legal Affairs (OAALA) of the Housing and Land Use Regulatory Board (HLURB). She requested an order requiring REVI to continue the sale of the house and lot and sought damages, including attorney's fees and exemplary damages. On August 17, 1990, the petition was amended to include Magdiwang Realty Corporation (MRC) as a co-petitioner, indicating that MRC was the registered owner of the property. The HLURB ruled in favor of Sendino, ordering compliance with the sale and awarding her damages.
Appeals and Legal Arguments
Following HLURB's decision, REVI appealed to the Office of the President, which ultimately dismissed the appeal. Petitioners contended that the HLURB lacked quasi-judicial functions as purportedly not defined by Executive Order No. 90 of December 17, 1986, and that their decision should have been rendered by the Board of Commissioners en banc. Petitioners also argued that the determination of the lot's nature and the proper cancellation procedure under Republic Act No. 6552 was mishandled.
Jurisdiction and Quasi-Judicial Functions
The court addressed the issue of the HLURB's jurisdiction and the extent of its quasi-judicial functions. It clarified that procedural rules for administrative bodies are more liberally construed than those for judicial proceedings. It considered the historical context of EO 85 and EO 90, asserting that the latter recognized the HLURB as a principal housing agency with necessary functions, which include settling disputes concerning land use and housing development as previously held by its predecessor, the Human Settlements Regulatory Commission (HSRC).
Decision on Petitioners' Arguments
The court found that the HLURB properly exercised its jurisdiction over the case. It reaffirmed that the HLURB's authority included adjudicative powers to settle disputes, including specific performance claims. Furthermore, petitioners' argument about the necessity of decisions being made en banc was rejected, as the Board had the authority to establish rules, including the capacity to delegate its adjudicatory functions to divided panels.
Application of Republic Act No. 6552
In relation to the petitioners' assertion that RA 6
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Background of the Case
- Private respondent Lucina C. Sendino entered into a reservation agreement with Realty Exchange Venture, Inc. (REVI) for a 120-square meter lot in Raymondville Subdivision, Sucat, Paranaque, at a purchase price of P307,800.00.
- The reservation fee payments included an initial P1,000.00 on January 15, 1989, completed with an additional P4,000.00 paid on January 20, 1989.
- On July 18, 1989, Sendino paid a full downpayment of P16,600.00.
- REVI requested Sendino to change her co-maker, which she agreed to, and sought an extension to submit the necessary documents.
Cancellation of Contract
- On July 31, 1989, REVI informed Sendino of the cancellation of the contract, citing non-compliance with the submission of documents as outlined in the original agreement.
- This cancellation led Sendino to file a complaint for Specific Performance against REVI on April 20, 1990, with the Office of Appeals, Adjudication and Legal Affairs (OAALA) of the Housing and Land Use Regulatory Board (HLURB).
Complaint Details
- Sendino sought the following remedies:
- An order for REVI to continue with the sale of the property.
- Compensation for actual, nominal, and moral damages.
- Payment of attorney's fees amounting to P10,000.00.
- Payment of P10,000.00 as exemplary damages.
Amended Complaint
- On August 17, 1990, Sendino amended her petition to include Magdiwang Realty Corporation (MRC), which was identified as the registered owner of the subject lot.
HLURB Decision
- On April 3, 1991,