G.R. No. 79622 September 29, 1989
ATTY. ENRIQUETO F. TEJADA, petitioner, vs. HOMESTEAD PROPERTY CORPORATION and TACLIN V. BAÑEZ, respondents.

FACTS

Petitioner Enriqueto F. Tejada paid a P20,000.00 reservation fee to respondents for a 200-square meter subdivision lot, with the understanding that the fee would form part of the purchase price if a final sale agreement was reached or be refunded if no agreement was made. The tentative terms set the price at P1,150.00 per square meter. However, when respondent corporation unilaterally altered the proposed amortization terms, petitioner refused to proceed with the purchase and demanded a refund of his reservation fee. Respondents refused to return the amount.
Petitioner subsequently filed a complaint for collection of a sum of money and damages with the Regional Trial Court (RTC) of Pasig. Respondents moved to dismiss the case, contending that jurisdiction properly lay with the Human Settlements Regulatory Commission (HSRC), now the Housing and Land Use Regulatory Board (HLRB). The RTC denied the motion to dismiss, a decision affirmed upon reconsideration. Respondents then filed a petition for certiorari with the Court of Appeals, which ruled that the HSRC/HLRB had exclusive jurisdiction over the case.

ISSUE

Whether the Regional Trial Court or the Housing and Land Use Regulatory Board (HLRB) has jurisdiction over an action for the refund of a reservation fee paid in connection with a proposed purchase of a subdivision lot.

RULING

The Supreme Court ruled that the HLRB has exclusive jurisdiction. The legal logic is anchored on Presidential Decree No. 1344, which conferred upon the National Housing Authority (NHA), and by subsequent transfer to the HSRC and then the HLRB, exclusive jurisdiction to hear and decide “claims involving refund and any other claims filed by subdivision lot or condominium unit buyers against the project owner, developer, dealer, broker or salesman.” The Court rejected petitioner’s argument that this jurisdiction applies only to perfected contracts of sale, holding that the term “buyer” in the law includes anyone who purchases or offers to purchase for money. Thus, a prospective buyer like the petitioner falls within this definition.
Furthermore, the Court emphasized that Executive Order No. 90, which transferred functions to the HLRB, eliminated any previous ambiguity by granting jurisdiction over “claims involving refund filed against project owners, developers, and dealers” without the qualifying phrase “by a buyer.” This clarification broadened the scope to include any claim for refund, irrespective of the claimant’s precise contractual status. The Court also endorsed the policy against split jurisdiction, noting that since the claim arose from a proposed purchase of a subdivision lot—a matter within the HLRB’s specialized regulatory field—all related controversies should be lodged with that quasi-judicial body. Consequently, the petition was dismissed for lack of merit.