GR 84811; (August, 1989) (Digest)
G.R. No. 84811 August 29, 1989
SOLID HOMES, INC., petitioner, vs. TERESITA PAYAWAL and COURT OF APPEALS, respondents.
FACTS
Teresita Payawal filed a complaint for delivery of title against Solid Homes, Inc. before the Regional Trial Court (RTC) of Quezon City. She alleged that after fully paying for a subdivision lot under a contract to sell, Solid Homes executed a deed of sale but failed to deliver the certificate of title because it had mortgaged the property. She sought specific performance or, alternatively, a refund of all payments with damages. Solid Homes moved to dismiss, asserting that jurisdiction lay with the National Housing Authority (NHA), now the Housing and Land Use Regulatory Board (HLURB), under Presidential Decree No. 957. The RTC denied the motion, proceeded to trial, and ruled in Payawal’s favor, ordering delivery of title or refund plus damages. The Court of Appeals affirmed, citing Section 41 of P.D. 957, which states that remedies under the decree are “in addition to” other existing laws, thus upholding the RTC’s concurrent jurisdiction.
ISSUE
Whether the Regional Trial Court or the Housing and Land Use Regulatory Board (formerly the National Housing Authority) has jurisdiction over a complaint filed by a subdivision lot buyer against the developer for specific performance (delivery of title) and damages.
RULING
The Supreme Court reversed the Court of Appeals and held that the HLURB has exclusive jurisdiction. The Court applied P.D. No. 1344, which explicitly empowers the NHA (now HLURB) with “exclusive jurisdiction to hear and decide” claims involving refunds and specific performance of obligations filed by subdivision buyers against developers. This special law prevails over the general jurisdiction granted to Regional Trial Courts under Batas Pambansa Blg. 129. The principle that a special law governs a specific subject matter over a general law applies regardless of the sequence of enactment. The Court found that Payawal’s action—a claim by a subdivision buyer against the developer for delivery of title—falls squarely under the categories enumerated in P.D. 1344. Consequently, the RTC decision was rendered without jurisdiction and is null and void. The case was dismissed without prejudice to refiling before the HLURB.