G.R. No. 94927 January 22, 1993
ROBERTO RUBIO ALCASID, CLARISSA A. RUBIO, ELENITA A. RUBIO, RUBEN RUBIO, PATRICIA RUBIO and EDUARDO RUBIO LAYGO, petitioners, vs. COURT OF APPEALS and SAMAHANG BUKLOD NG BARANGAY IV & VI, rep. by its President Rosalina de Rosas, Jesus Ostonol, Armando Palmencio, Gaudioso Calabia, Angel Santos, Aurelio Miranda, Nicanor Edroso, Hipolito Reyes, Marcelo B. Cruz and Maria Gonzales, respondents.

FACTS

On December 3, 1984, private respondents filed a complaint-affidavit with the National Housing Authority (NHA, now HLURB) to compel Eduardo Laygo, administrator of a property, to execute contracts of sale for lots they occupied and on which they claimed to have made partial payments, alleging the property was a subdivision project subject to PD 957, PD 1216, and PD 1344. On March 22, 1985, they filed a complaint for estafa and violation of PD 957 with the Laguna Provincial Fiscal’s Office against Laygo, which was later dismissed. On May 15, 1987, the HLURB Enforcement Office ordered Laygo to register the land as a subdivision, obtain a license to sell, and pay a fine. On June 16, 1988, private respondents organized into Samahang Buklod ng Barangay IV and VI and filed a class suit in the Regional Trial Court (RTC) of Laguna seeking annulment and cancellation of titles, reconveyance, execution of contracts of sale, fixing of purchase price per subdivision laws, and introduction of necessary facilities. Petitioners filed a motion to dismiss on grounds including a pending action before the HLURB involving the same parties and issues. The RTC denied the motion on March 16, 1989, stating the HLURB case was a criminal complaint and had been dismissed. Petitioners appealed via certiorari to the Court of Appeals, which on June 28, 1990, ruled the order was interlocutory and not subject to certiorari, and that the RTC had jurisdiction under BP 129, Sec. 19, over actions involving title to or possession of real property.

ISSUE

Whether the Regional Trial Court or the Housing and Land Use Regulatory Board (HLURB) has exclusive jurisdiction over the complaint filed by private respondents, which involves demands for specific performance of contractual and statutory obligations related to a subdivision project.

RULING

The Supreme Court reversed the decision of the Court of Appeals and dismissed the civil case in the RTC for lack of jurisdiction. The Court held that exclusive jurisdiction rests with the HLURB under PD 1344, Sec. 1, which grants the HLURB exclusive jurisdiction over cases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots. The Court found that the complaint, by its allegations, plainly involved a subdivision project, as private respondents demanded the introduction of facilities like asphalting and street lights, and sought execution of contracts of sale and fixing of purchase price in line with subdivision laws. The characterization of an action is determined by the allegations in the complaint, not its caption. The Court emphasized that the HLURB, as an administrative agency, exercises quasi-judicial powers over matters within its special expertise, such as subdivision regulation. Since the complaint falls under PD 1344, the RTC had no jurisdiction, and the motion to dismiss should have been granted.