G.R. No. 79622 September 29, 1989
ATTY. ENRIQUETO F. TEJADA, petitioner, vs. HOMESTEAD PROPERTY CORPORATION and TACLIN V. BAÑEZ, respondents.

FACTS

Petitioner Enriqueto F. Tejada paid a P20,000.00 reservation fee to respondents for a 200-square meter subdivision lot, with the understanding that the fee would form part of the purchase price if a final sale agreement was reached or be refunded if no agreement was made. The tentative terms set the price at P1,150.00 per square meter. However, when respondent corporation unilaterally altered the proposed amortization terms, petitioner refused to proceed with the purchase and demanded a refund of his reservation fee. Respondents refused to return the amount.
Petitioner filed a complaint for collection of a sum of money with damages in the Regional Trial Court (RTC) of Pasig. Respondents moved to dismiss, contending that jurisdiction over the case lay with the Human Settlements Regulatory Commission (HSRC), now the Housing and Land Use Regulatory Board (HLRB). The RTC denied the motion. On certiorari, the Court of Appeals reversed, ruling that the HSRC/HLRB had exclusive jurisdiction. Petitioner now argues before the Supreme Court that since no perfected contract of sale existed, his claim for a refund is a simple collection case within the jurisdiction of regular courts.

ISSUE

Whether the Regional Trial Court or the Housing and Land Use Regulatory Board (HLRB) has jurisdiction over an action for the refund of a reservation fee paid in relation to a proposed purchase of a subdivision lot.

RULING

The Supreme Court ruled that the HLRB has exclusive jurisdiction. The legal logic is anchored on Presidential Decree No. 1344, which conferred upon the National Housing Authority (NHA), and by subsequent transfers to the HSRC and then the HLRB, the exclusive jurisdiction to hear and decide “claims involving refund and any other claims filed by subdivision lot or condominium unit buyers against the project owner, developer, dealer, broker or salesman.” The Court emphasized that the law draws no distinction between a perfected sale and an unperfected one; the term “buyer” encompasses anyone who purchases or offers to purchase for money. Thus, petitioner, who offered to buy the lot, qualifies as a buyer under the decree.
Furthermore, the Court noted that Executive Order No. 90, which transferred functions to the HLRB, eliminated the specific reference to “buyers,” thereby clarifying that any claim for refund against a project owner or developer falls within the HLRB’s exclusive jurisdiction, regardless of the claimant’s precise contractual status. The policy against split jurisdiction favors vesting an administrative body, with its specialized competence over real estate trade matters, with authority over all related controversies. Since the claim arose from a proposed purchase of a subdivision lot, it pertains to the HLRB’s specialization. The petition was dismissed for lack of merit.