G.R. No. 166051 ; April 8, 2008
SOLID HOMES, INC., petitioner, vs. EVELINA LASERNA and GLORIA CAJIPE, represented by PROCESO F. CRUZ, respondents.
FACTS
Respondents Evelina Laserna and Gloria Cajipe entered into a Contract to Sell with petitioner Solid Homes, Inc. (SHI) for a subdivision lot. After making the down payment and several monthly installments, respondents claimed to have paid 90% of the purchase price. They demanded the execution of a Deed of Sale and delivery of the title upon payment of the alleged final balance. SHI refused, contending the respondents had not fully paid and considered the contract rescinded for non-payment. Respondents filed a complaint for delivery of title and execution of a deed of sale with damages before the Housing and Land Use Regulatory Board (HLURB).
The HLURB Arbiter initially denied the immediate issuance of the deed but ordered SHI to execute it upon full payment. The HLURB Board of Commissioners modified this, directing respondents to pay a specified balance within 30 days and SHI to execute the deed and deliver the title immediately upon that full payment. SHI appealed to the Office of the President, which affirmed the HLURB Board’s decision in toto, adopting its findings by reference. The Court of Appeals subsequently denied SHI’s petition.
ISSUE
The core issues were: (1) Whether the Office of the President’s decision, which adopted the HLURB’s findings by reference, complied with the constitutional requirement that decisions must state the facts and the law on which they are based; and (2) Whether the Court of Appeals erred in not dismissing the complaint for lack of cause of action.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. On the first issue, the Court held that the Office of the President’s decision complied with legal standards. While the Constitution and the Judiciary Reorganization Act require decisions to state clearly and distinctly the findings of fact and conclusions of law, this requirement is satisfied if the decision itself sets forth these findings or adopts them by reference from the lower tribunal’s decision. The Office of the President explicitly affirmed and adopted the HLURB Board’s findings, which contained a complete factual and legal basis. This adoption by reference is permissible and does not violate due process.
On the second issue, the Court found no merit in SHI’s claim that respondents had no cause of action. The HLURB correctly determined the exact outstanding balance owed by the respondents. The directive for respondents to pay this balance as a precondition for SHI’s execution of the deed was a proper recognition of the reciprocal obligations under the contract. SHI’s unilateral declaration of rescission was invalid as it was not judicially assented to by the respondents, who were not in substantial breach. Therefore, the respondents had a valid cause of action to compel compliance with the contract terms upon payment of the determined balance.
