G.R. No. 182707; September 1, 2010
SPOUSES ERNESTO LIM and ZENAIDA LIM, Petitioner, vs. RUBY SHELTER BUILDERS AND REALTY DEVELOPMENT CORPORATION, Respondent.

FACTS

In May 2001, petitioners Spouses Lim purchased a 318-square meter portion of a larger lot in Naga City from respondent Ruby Shelter, a licensed realty developer, for ₱190,000. The respondent undertook to subdivide the lot and, upon approval of the subdivision plan by the Bureau of Lands, execute a deed of absolute sale. In December 2001, Ruby Shelter delivered the deed of sale and promised to deliver the corresponding title after plan approval. The subdivision plan was subsequently approved, segregating the lot sold to the Lims as Lot 9-E-2-B. However, Ruby Shelter failed to deliver the title despite demands.
The Lims filed an action for delivery of title with damages before the Housing and Land Use Regulatory Board (HLURB), which ruled in their favor. The Office of the President affirmed this decision. Ruby Shelter’s motion for reconsideration was denied, and the decision was declared final and executory. Nevertheless, Ruby Shelter filed a petition with the Court of Appeals, which granted the petition, ruling that the HLURB lacked jurisdiction over the case, prompting this appeal.

ISSUE

Whether the HLURB has jurisdiction over the Lims’ action for specific performance to compel the delivery of title.

RULING

Yes, the HLURB has jurisdiction. Jurisdiction over the subject matter is determined by the allegations in the complaint and the applicable law in light of established facts. Presidential Decree No. 1344, which empowers the HLURB, grants it exclusive jurisdiction over cases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots against the developer. The law aims to regulate practices like the failure to deliver titles.
Applying the law to the facts, the transaction falls within HLURB’s jurisdiction. Ruby Shelter, as a licensed land developer, sold a portion of a lot it subdivided. Its refusal to deliver the title, without any valid excuse, constitutes a clear case for specific performance by subdivision lot buyers against a developer. The Court rejected Ruby Shelter’s argument that the transaction was outside HLURB’s purview merely because the original lot was only subdivided into four portions, not a large-scale subdivision. The controlling factor is that the seller is a licensed developer whose dealings are regulated by the HLURB, and the buyers relied on its statutory and contractual duties.
Furthermore, the Court noted that the CA gravely erred in entertaining Ruby Shelter’s petition, as the decision of the Office of the President had already attained finality. Consequently, the Supreme Court reversed the CA decision and reinstated the rulings of the Office of the President and the HLURB.