GR 187978; (November, 2010) (Digest)
G.R. No. 187978 ; November 24, 2010
ROMULO R. PERALTA, Petitioner, vs. HON. RAUL E. DE LEON, Presiding Judge, Regional Trial Court of Parañaque, Branch 258, HON. ARBITER DUNSTAN SAN VICENTE, in his capacity as Housing and Land Use Regulatory Arbiter and LUCAS ELOSO EJE, in his capacity as Sheriff, Regional Trial Court, Parañaque City and CONCEPTS AND SYSTEM DEVELOPMENT INC., as represented by its CHAIRMAN KASUO NORO, Respondents.
FACTS
Petitioner Romulo R. Peralta entered into a Contract to Sell with respondent Concepts and System Development Inc. (CSDI) for a condominium unit. Petitioner failed to pay the full purchase price. Consequently, CSDI filed a complaint for collection/specific performance against petitioner before the Housing and Land Use Regulatory Board (HLURB), which was decided in CSDI’s favor. The HLURB ordered petitioner to pay the balance with interest or, in case of failure, suffer rescission of the contract and forfeiture of payments. This HLURB decision became final and executory.
Separately, petitioner, with other unit owners, filed a complaint against CSDI before the HLURB for various violations related to the condominium project’s development. While this second HLURB case was pending, petitioner filed a Complaint for Annulment of the first HLURB judgment and the Certificate of Title issued to CSDI before the Regional Trial Court (RTC). The RTC dismissed this complaint on grounds of lack of jurisdiction and forum shopping.
ISSUE
Whether the Regional Trial Court correctly dismissed petitioner’s Complaint for Annulment of Judgment on the grounds of lack of jurisdiction and forum shopping.
RULING
Yes, the RTC correctly dismissed the Complaint. The Supreme Court affirmed that jurisdiction over the case lies with the HLURB, not the regular courts. The controversy arose from a contract of sale of a condominium unit, which falls squarely within the HLURB’s exclusive jurisdiction to regulate the real estate trade and adjudicate claims filed by buyers of subdivision lots or condominium units against developers, under Presidential Decree No. 957 and its amendatory laws. Petitioner’s attempt to annul the final HLURB decision and the resulting title via an RTC action was an improper collateral attack on a final judgment rendered by a quasi-judicial body with competent jurisdiction.
Furthermore, the Court found that petitioner committed forum shopping. He filed the RTC case while his appeal from the adverse HLURB decision in the separate but related case filed by the unit owners’ group was still pending. This constituted splitting causes of action and seeking recourse in two different fora for relief arising from the same transaction, which is prohibited. The dismissal by the RTC and the affirmance by the Court of Appeals were therefore proper. The HLURB’s decision had attained finality and must be respected.
