G.R. No. 131903 ; June 26, 2008
OSCAR R. BADILLO, ET AL., petitioners, vs. COURT OF APPEALS, REGISTER OF DEEDS OF QUEZON CITY, ET AL., respondents.

FACTS

Petitioners, owners of lots adjoining a road lot (Lot 369-A-29 or Apollo Street), filed a complaint for Annulment of Documents with Damages. They alleged that respondent Pedro del Rosario, the registered owner of the road lot, violated a court order annotated on his title prohibiting the lot’s closure or disposal without prior court approval. Del Rosario sold portions of the lot to co-respondents Josefa Conejero and Ignacio Sonoron, and they executed a partition agreement leading to the issuance of new titles. Del Rosario later sold his portion to respondent Goldkey Development Corporation, which built fences, blocking petitioners’ access. Petitioners argued the Register of Deeds violated the court order by registering these transactions without judicial approval.
Prior to the court case, petitioners initiated a complaint with the Office of the Building Official of Quezon City (Building Case No. R-10-91-006) when Goldkey began construction. The Building Official resolved the case against petitioners, declaring the property a residential lot, not a road lot, and this decision became final. Furthermore, the HLURB had issued a Development Permit to Goldkey for a townhouse project on the land. Petitioners did not appeal either the Building Official’s decision or the HLURB’s permit.

ISSUE

Whether the Regional Trial Court correctly dismissed the case for lack of jurisdiction over the subject matter.

RULING

Yes. The Supreme Court affirmed the dismissal. Jurisdiction over the subject matter is conferred by law. The core of petitioners’ complaint was to enforce the obligation to preserve a subdivision road lot, alleging illegal conversion and disposition. This matter falls under the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB) pursuant to Presidential Decree Nos. 957, 1216, and 1344, which empower the HLURB to regulate subdivisions and hear cases involving unsound real estate business practices. The regular courts have no jurisdiction.
Moreover, the factual premise of petitioners’ claim—that the property is a road lot—had been conclusively settled by the final and executory decision of the Quezon City Building Official, which declared it a residential lot. The HLURB’s issuance of a development permit reinforced this classification. Petitioners’ failure to appeal these administrative rulings rendered them binding. The Court also noted that the petition for certiorari was improperly used as a substitute for a lost appeal under Rule 45, as petitioners received the Court of Appeals’ decision in October 1997 but filed the petition only in December 1997, beyond the reglementary period. No compelling reason justified a liberal application of procedural rules in this case.