GR 135442; (August, 2000) (Digest)
G.R. No. 135442 ; August 31, 2000
MA. LOUISA T. QUE, petitioner, vs. COURT OF APPEALS, RTC-Br. 158, PASIG CITY, and NICOLAAS J. KLAVER, respondents.
FACTS
Nicolaas Klaver filed a Complaint for specific performance and damages against Ma. Louisa Que before the RTC, alleging she violated their Conditional Deed of Sale over a condominium unit by failing to pay the full price and taking possession without his consent. Klaver later amended his Complaint to implead the developer, Golden Dragon Real Estate Corporation (GDREC), and its officers. Que moved to dismiss, arguing that impleading GDREC transformed the case into one cognizable by the Housing and Land Use Regulatory Board (HLURB), stripping the RTC of jurisdiction.
Klaver then filed a Manifestation seeking to dismiss his claims against GDREC without prejudice and subsequently lodged a separate complaint against GDREC before the HLURB for unsound real estate practices. The RTC issued an Order dismissing the claims against GDREC, denying Que’s Motion to Dismiss, and admitting an Amended Complaint solely against Que. Que challenged this Order via certiorari in the Court of Appeals, which denied her petition.
ISSUE
Whether the trial court retained jurisdiction over Klaver’s case against Que despite the initial amendment that included GDREC as a defendant.
RULING
The Supreme Court denied Que’s petition, affirming the trial court’s jurisdiction. Jurisdiction is conferred by law and determined by the allegations in the complaint. Klaver’s original Complaint alleged facts constituting a cause of action for specific performance and damages against Que based on their contract, which is within the general jurisdiction of the RTC. The subsequent amendment to include GDREC did not divest the RTC of this jurisdiction. The amendment was not a substitution but an expansion, and Klaver’s cause of action against Que remained distinct and independent. His act of dropping GDREC from the RTC case was a permissible correction of a misjoinder of parties, not a jurisdictional flaw.
However, the Court modified the ruling, directing the trial court to defer proceedings until the related HLURB case is finally resolved. The HLURB had already found that Que had overpaid Klaver, a finding potentially conclusive on the rights over the property. To avoid conflicting decisions, the trial court must await the final outcome of the HLURB case, which directly impacts the merits of Klaver’s claims against Que.