G.R. No. 169706, February 5, 2010
SPOUSES WILLIAM GENATO and REBECCA GENATO, Petitioners, vs. RITA VIOLA, Respondent.

FACTS

In October 1991, a complaint was filed with the Housing and Land Use Regulatory Board (HLURB) titled “VILLA REBECCA HOMEOWNERS ASSOCIATION, INC. versus MR. WILLIAM GENATO and spouse REBECCA GENATO.” The complaint was verified by 34 individuals, including respondent Rita Viola, who identified themselves as the “Complainants” who caused its preparation. The complaint alleged that the complainants had executed Contracts to Sell and/or Lease Purchase Agreements with petitioners Spouses Genato for housing units. After a lifted cease and desist order, the Spouses Genato refused to accept amortization payments and demanded a lump sum for accrued amortizations. The complaint prayed for various reliefs, including acceptance of payments without penalty, correction of construction deficiencies, and provision of water facilities.
On March 8, 1995, the Housing Arbiter rendered a decision ordering complainants to resume payments and directing the Spouses Genato to correct construction deficiencies and provide water facilities. On appeal, the HLURB Board of Commissioners modified the decision, ordering complainants to pay 3% interest per month for unpaid amortizations from June 29, 1991, and directing the Spouses Genato to accept payments, provide drainage and water facilities, and reimburse certain costs. This decision became final and executory.
On May 26, 2000, a Writ of Execution was issued. The sheriff seized respondent Viola’s two delivery trucks and 315 sacks of rice. Viola filed a motion to quash the execution. The trucks were released, but the 315 sacks of rice were sold at public auction to petitioner Rebecca Genato for ₱189,000. The Arbiter denied Viola’s motion and directed her to pay ₱739,133.31. On appeal, the HLURB First Division granted the motion to quash, set aside the Arbiter’s orders, and directed the Spouses Genato to credit Viola’s account with the value of the rice, which it determined to be ₱318,500. The Office of the President and the Court of Appeals affirmed this decision.

ISSUE

1. Whether the HLURB acquired jurisdiction over the person of respondent Rita Viola.
2. Whether the HLURB could rule on lack of jurisdiction over Viola’s person after its decision became final and executory.
3. Whether Viola can claim an amount higher than the price stated in the Sheriff’s Certificate of Sale for the auctioned rice.
4. Whether the doctrine on the binding effect of findings of fact by an adjudicative body is applicable.

RULING

1. Yes, the HLURB acquired jurisdiction over the person of respondent Rita Viola. The Court ruled that it is not the caption of the pleading but the allegations therein that are controlling. Although the complaint was titled in the name of the Homeowners Association, the body stated that 34 individuals, including Viola, were the complainants who caused its preparation. The rules of pleading require courts to look beyond form and into substance. The non-inclusion of all names in the title is a formal, not a jurisdictional, defect. Viola, by actively participating in the proceedings through verification of the complaint and seeking affirmative relief, voluntarily submitted to the HLURB’s jurisdiction. Her subsequent acts, including filing motions and appeals, estopped her from denying the HLURB’s jurisdiction over her person.
2. The HLURB could no longer rule on the issue of jurisdiction over Viola’s person after its decision became final and executory. The principle of conclusiveness of judgment applies. A final and executory judgment is immutable and unalterable. The HLURB’s initial decision had long become final; thus, it could not be modified or set aside by the HLURB itself on the ground of lack of jurisdiction over a party who had voluntarily participated.
3. No, Viola cannot claim an amount higher than the auction price stated in the Sheriff’s Certificate of Sale. The best evidence of the value of the auctioned rice is the Sheriff’s Certificate of Sale. The HLURB’s determination of a higher value (₱318,500) lacked evidentiary basis. Since the levy and auction were deemed valid (as jurisdiction over Viola existed), the price obtained at the public auction governs.
4. The doctrine on the binding effect of findings of fact is not applicable here. While findings of fact by specialized bodies like the HLURB are generally conclusive, this holds true only when supported by substantial evidence. The HLURB’s conclusion that it lacked jurisdiction over Viola was not supported by substantial evidence, as the record clearly showed her voluntary submission to its jurisdiction.
The petition was GRANTED. The assailed Court of Appeals Decision was REVERSED and SET ASIDE. The HLURB Orders denying the motion to quash the writ of execution and directing Rita Viola to pay the Spouses Genato were REINSTATED.