G.R. No. 144892. September 23, 2005.
SPS. CARLOS J. SUNTAY and ROSARIO R. SUNTAY, Petitioners, vs. EUGENIA D. GOCOLAY and DUNSTAN T. SAN VICENTE, Respondents.

FACTS

Petitioners Suntay and respondent Gocolay were both buyers of condominium units from developer Bayfront Development Corporation. After Bayfront failed to deliver the units, the Suntays filed a successful case against it before the HLURB. To satisfy the judgment, Bayfront’s properties, including a specific condominium unit, were levied and sold at public auction, with the Suntays as the highest bidders. A new title was eventually issued in their name. Gocolay, however, claimed she had earlier purchased the same unit from Bayfront, having completed payments in 1991, and received a deed of absolute sale and the original title in November 1995—after the levy and auction in favor of the Suntays had already been annotated on that title. Gocolay filed a complaint with the HLURB against the Suntays and others, seeking annulment of the auction sale, cancellation of the notice of levy from her title, and damages. The HLURB Arbiter ruled in Gocolay’s favor, declaring the auction sale null and void. The Court of Appeals later dismissed the Suntays’ petition challenging this HLURB decision.

ISSUE

Whether the Housing and Land Use Regulatory Board (HLURB) has jurisdiction over Gocolay’s action for annulment of an auction sale, cancellation of a notice of levy, and damages, which arose from a dispute between two buyers over a condominium unit acquired from a developer.

RULING

No, the HLURB does not have jurisdiction. The Supreme Court reversed the Court of Appeals and nullified the HLURB’s decision. The Court clarified that the HLURB’s jurisdiction under PD 957 and PD 1344 is limited to cases aimed at compelling a subdivision or condominium developer to comply with its legal and contractual obligations to buyers. The dispute between the Suntays and Gocolay had transcended this scope. It was no longer a case of a buyer against a developer, but a conflict between two purchasers over the ownership of a specific property arising from an execution sale conducted by a sheriff. Such an action, which essentially involves the annulment of a levy and auction sale and the determination of rights to real property, is incapable of pecuniary estimation and falls under the exclusive original jurisdiction of the Regional Trial Court pursuant to Section 19 of Batas Pambansa Blg. 129. The HLURB, as a quasi-judicial body of limited jurisdiction, cannot adjudicate this type of controversy. The inclusion of the developer as a party did not vest jurisdiction, as the core issue was the validity of the sheriff’s auction and the conflicting claims of ownership between the two private parties.