G.R. No. 171399 ; May 8, 2009
VICENTA CANTEMPRATE, ET AL., Petitioners, vs. CRS REALTY DEVELOPMENT CORPORATION, ET AL., Respondents.

FACTS

Petitioners are buyers of subdivision lots from respondent CRS Realty Development Corporation. They filed a complaint with the Housing and Land Use Regulatory Board (HLURB) against the developer and the landowner, Cesar Casal, for the delivery of certificates of title after having fully paid their lots. They later amended their complaint to implead Bennie Cuason and Caleb Ang, to whom Casal had transferred the property, and prayed for the nullification of that deed of sale and the reconveyance of the lots to them. Petitioners alleged that the transfer was fraudulent and designed to deprive them of their rights.
Respondents raised various defenses, including that the obligation to deliver titles fell on the developer, and that a notice of lis pendens from a separate civil case involving the Heirs of Laudiza prevented the clean transfer of titles. The HLURB Arbiter initially ruled in favor of petitioners, finding fraud in the subsequent sale and ordering the delivery of titles. However, the HLURB Board of Commissioners reversed this, dismissing the complaint for lack of jurisdiction, a ruling affirmed by the Office of the President and the Court of Appeals.

ISSUE

Whether the HLURB has jurisdiction over the petitioners’ complaint, which sought not only the delivery of titles but also the nullification of a deed of sale and the reconveyance of property.

RULING

No, the HLURB does not have jurisdiction. The Supreme Court affirmed the dismissal, holding that while the HLURB has exclusive jurisdiction over cases filed by subdivision buyers against developers for specific performance of statutory and contractual obligations, such as the delivery of titles, the nature of the amended complaint in this case placed it beyond the HLURB’s authority. By praying for the declaration of their lawful ownership, the annulment of the deed of absolute sale between Casal and the new buyers (Ang and Cuason), and the reconveyance of the property, the petitioners essentially raised an action to quiet title. The Court ruled that such an action, which directly involves the resolution of ownership and the validity of a transfer of registered land, falls within the exclusive original jurisdiction of the Regional Trial Courts under Section 19(2) of Batas Pambansa Blg. 129. The HLURB’s adjudicatory power is limited to the regulatory aspects of subdivision development and sales under P.D. No. 957 and cannot extend to settling disputes over title ownership between conflicting claimants.