G.R. No. 98023 October 17, 1991
Multinational Village Homeowners’ Association, Inc. vs. Court of Appeals and Multinational Realty and Development Corporation

FACTS

Private respondent Multinational Realty and Development Corporation filed a complaint in the Regional Trial Court of Makati against petitioner Multinational Village Homeowners’ Association, Inc. and a security agency. The Corporation alleged it owned a road connecting Multinational Village to Ninoy Aquino Avenue. It claimed that while it had permitted the Association to use the road and erect a guardhouse, the Association was now preventing the Corporation from using the same road to transport construction materials for developing its adjacent properties. The complaint sought enforcement of ownership rights, injunction, and damages.
The trial court granted preliminary injunctions, prohibiting the Association from blocking the Corporation’s use of the road and ordering the guardhouse’s removal. The Association moved to dismiss the civil case, arguing the Housing and Land Use Regulatory Board (HLURB) had exclusive jurisdiction under P.D. 957 and that a prior administrative case between the parties before the HLURB, then on appeal to the Office of the President, barred the suit. The motion was denied. The Court of Appeals subsequently denied the Association’s certiorari petition, prompting this appeal.

ISSUE

Whether the Regional Trial Court, not the HLURB, has jurisdiction over the complaint for enforcement of ownership rights over the disputed road.

RULING

The Supreme Court ruled that the Regional Trial Court correctly exercised jurisdiction. Jurisdiction is determined by the allegations in the complaint, not by the defenses in the answer. The Corporation’s complaint directly asserted a claim of ownership over the property and sought to enforce the attendant rights, such as possession and use. This is a classic real action cognizable by regular courts under the Civil Code.
The case does not fall under the exclusive jurisdiction of the HLURB as defined in Section 1 of P.D. 957. That law covers cases involving unsound business practices, claims for refund, and specific performance of statutory or contractual obligations filed by subdivision buyers against developers. The Corporation’s action is not a claim by a buyer but an action by the alleged owner to vindicate a property right. The Association’s defense that the road is reserved for village residents’ exclusive use does not transform the case’s nature or divest the trial court of jurisdiction.
Furthermore, the pending administrative case before the HLURB does not constitute litis pendentia. The causes of action differ: the administrative case involves the Association’s claim for specific performance by the Corporation to provide subdivision facilities, while the civil case involves the Corporation’s claim of being denied use of its property. There is no identity of causes of action or subject matter. The charge of forum-shopping also fails, as the Corporation filed the civil case due to the immediate denial of access to the road, not to anticipate an unfavorable ruling in the unrelated administrative appeal.