G.R. No. 80916 November 9, 1990
C.T. TORRES ENTERPRISES, INC., petitioner, vs. HON. ROMEO J. HIBIONADA, EFREN DIONGON, and PLEASANTVILLE DEVELOPMENT CORPORATION, respondents.

FACTS

Petitioner C.T. Torres Enterprises, Inc., acting as agent for respondent Pleasantville Development Corporation, sold a subdivision lot on installment to respondent Efren Diongon. Upon completion of the installment payments, Diongon demanded the delivery of the certificate of title. When both the petitioner and Pleasantville failed to comply, Diongon filed a complaint for specific performance and damages against them in the Regional Trial Court (RTC) of Negros Occidental. The case proceeded with the filing of answers, cross-claims, counterclaims, a reply, pre-trial, and the submission of trial briefs.
After the case was set for initial hearing, petitioner filed a motion to dismiss on the ground of lack of jurisdiction. It contended that, under Executive Order No. 90, the Housing and Land Use Regulatory Board (HLURB) had exclusive jurisdiction over the case. The RTC denied the motion, ruling that the complaint for specific performance with damages was a justiciable issue under the Civil Code and thus within the jurisdiction of regular courts under Batas Pambansa Blg. 129. Petitioner elevated the matter to the Supreme Court via certiorari.

ISSUE

Whether the Regional Trial Court or the Housing and Land Use Regulatory Board has jurisdiction over a complaint for specific performance and damages filed by a subdivision lot buyer against the seller/developer for failure to deliver the certificate of title.

RULING

The Supreme Court granted the petition, ruling that the HLURB has exclusive jurisdiction. The legal logic is anchored on the statutory framework governing subdivision sales. Presidential Decree No. 957, the Subdivision and Condominium Buyers’ Protective Decree, vested the National Housing Authority (NHA) with exclusive authority to regulate the real estate trade and business, specifically to address failures to deliver titles and other fraudulent practices. This regulatory and quasi-judicial authority was explicitly defined in P.D. No. 1344, Section 1(c), which grants the NHA (and its successor agency, the HLURB) exclusive jurisdiction over “[c]ases involving specific performance of contractual and statutory obligations filed by buyers of subdivision lots or condominium units against the owner, developer, dealer, broker or salesman.”
The Court rejected the trial court’s view that only regular courts can adjudicate claims under the Civil Code. It emphasized that the growing complexity of society necessitates the vesting of quasi-judicial powers in specialized administrative agencies like the HLURB, which can resolve disputes within their expertise with more dispatch. The Court cited its precedent in Solid Homes, Inc. v. Payawal, which affirmed the HLURB’s competence to award damages, a power traditionally judicial. Since Diongon’s claim arose from a subdivision sale and sought specific performance of the obligation to deliver title, it fell squarely within the HLURB’s exclusive jurisdiction under P.D. No. 1344. Consequently, the RTC order was set aside and the case was dismissed without prejudice to its refiling with the HLURB.