G.R. No. 137869 & 137940 ; June 12, 2008
SPOUSES MARCIAL VARGAS and ELIZABETH VARGAS, petitioners, vs. SPOUSES VISITACION and JOSE CAMINAS, SPOUSES JESUS and LORELEI GARCIA, and SPOUSES RODOLFO and ROSARIO ANGELES DE GUZMAN, respondents. / SPOUSES RODOLFO and ROSARIO ANGELES DE GUZMAN, petitioners, vs. SPOUSES VISITACION and JOSE CAMINAS, and SPOUSES MARCIAL and ELIZABETH VARGAS, respondents.

FACTS

Spouses Jose and Visitacion Caminas purchased a townhouse from developer Jesus Garcia in 1988, paying P850,000 and taking possession upon construction. In 1990, Garcia, who had also executed a deed of sale for a different townhouse to spouses Marcial and Elizabeth Vargas as payment for construction materials, exchanged that property with the Vargas spouses for the very townhouse he had sold to the Caminas spouses. None of these sales were registered. Subsequently, Garcia mortgaged the disputed townhouse to spouses Rodolfo and Rosario Angeles De Guzman, who later foreclosed and acquired the title.
Spouses Caminas filed a complaint for nullity of deeds and declaration of ownership against the Garcia, De Guzman, and Vargas spouses. The Vargas spouses filed a separate but related action. The cases were consolidated. During proceedings, spouses Vargas raised the trial court’s lack of jurisdiction, asserting that the Housing and Land Use Regulatory Board (HLURB) had exclusive jurisdiction and had already decided a case in their favor. The trial court initially ruled for the Caminas spouses but, on reconsideration, awarded ownership to the De Guzman spouses. The Court of Appeals reversed and reinstated the first decision favoring the Caminas spouses.

ISSUE

Whether the Regional Trial Court had jurisdiction over the consolidated cases for declaration of ownership and nullity of deeds involving the sale of a subdivision townhouse.

RULING

The Supreme Court ruled that the Regional Trial Court had no jurisdiction; exclusive jurisdiction was vested in the HLURB. The legal logic is anchored on the nature of the controversy and applicable laws. Presidential Decree No. 957, as amended, grants the HLURB exclusive jurisdiction over cases involving the sale of subdivision lots and condominiums, including claims for specific performance and rescission of contracts with real estate developers. The dispute originated from sales executed by a subdivision developer, Garcia, making it intrinsically linked to the regulation of subdivision and condominium sales. The Court emphasized that jurisdiction is determined by the allegations in the complaint and the law at the time of filing. Since the complaints filed by both the Caminas and Vargas spouses essentially arose from transactions with a subdivision developer, they fell squarely within the HLURB’s regulatory purview. Consequently, the trial court’s assumption of jurisdiction was void. The Court set aside the Court of Appeals’ decision and dismissed the civil cases without prejudice to the parties seeking relief before the proper forum, the HLURB.