GR L 50444; (August, 1987) (Digest)
G.R. No. L-50444 August 31, 1987
ANTIPOLO REALTY CORPORATION, petitioner, vs. THE NATIONAL HOUSING AUTHORITY, HON. G.V. TOBIAS, in his capacity as General Manager of the National Housing Authority, THE HON. JACOBO C. CLAVE, in his capacity as Presidential Executive Assistant and VIRGILIO A. YUSON, respondents.
FACTS
Petitioner Antipolo Realty Corporation sold a subdivision lot to Jose Hernando under a Contract to Sell. Hernando later assigned his rights to respondent Virgilio Yuson, who assumed the vendee’s obligations. Due to Antipolo Realty’s failure to complete the subdivision improvements stipulated in Clause 17 of the contract within two years, Yuson rightfully suspended his monthly installment payments starting September 1972. In October 1976, Antipolo Realty notified Yuson that the improvements were complete and demanded resumption of payments, including accrued installments from September 1972 to October 1976 totaling P16,994.73. Yuson refused to pay the accrued installments but agreed to pay future ones. Antipolo Realty then rescinded the contract and declared forfeiture of all prior payments.
ISSUE
The primary issue is whether the National Housing Authority (NHA) had jurisdiction to adjudicate the complaint filed by Yuson regarding the rescission of the Contract to Sell.
RULING
The Supreme Court upheld the NHA’s jurisdiction. The Court ruled that under Presidential Decree No. 957, the NHA is vested with regulatory and adjudicatory authority over subdivision and condominium buyers’ complaints. This grant includes the power to hear and decide specific controversies between subdivision developers and lot buyers, such as the validity of a rescission based on contractual breaches. The law aims to provide a speedy, accessible, and specialized forum for aggrieved buyers. The Court found that Yuson’s suspension of payments was a valid exercise of his right under Clause 17 due to Antipolo Realty’s initial non-compliance. Consequently, Antipolo Realty’s subsequent rescission based on non-payment of the suspended installments was invalid. The NHA correctly ordered the contract’s reinstatement, requiring Yuson to pay only the installments falling due after the improvements were completed, without penalties. The Court affirmed that administrative agencies like the NHA can exercise quasi-judicial functions when explicitly empowered by law to do so.