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 from September 1972. In 1976, Antipolo Realty notified Yuson that the improvements were complete and demanded resumption of payments, including accrued installments from the suspension period totaling P16,994.73. Yuson agreed to pay only future installments, refusing to pay the accrued amounts. Antipolo Realty consequently rescinded the contract and declared forfeiture of all prior payments.
Yuson filed a complaint with the National Housing Authority (NHA). After hearing, the NHA ordered the reinstatement of the Contract to Sell, requiring Yuson to pay only the arrears from November 1976 onward, without penalty, and giving him sixty days to pay. Antipolo Realty’s motion for reconsideration was denied. Its subsequent petition to the Supreme Court (G.R. No. L-49051) was denied without prejudice to pursuing administrative appeal. The Office of the President affirmed the NHA decision.

ISSUE

Whether the NHA had jurisdiction to hear and decide the complaint for reinstatement of the Contract to Sell.

RULING

Yes, the NHA validly exercised its jurisdiction. The Court ruled that the NHA, under Presidential Decree No. 957 (The Subdivision and Condominium Buyers’ Protective Decree), possesses regulatory and adjudicatory authority over disputes between subdivision developers and lot buyers. The law empowers the NHA to regulate the real estate trade and subdivision development, which inherently includes the authority to resolve specific controversies arising from contracts to sell, such as the propriety of a developer’s rescission based on a buyer’s suspension of payments due to the developer’s own contractual breach. The Court emphasized that administrative agencies like the NHA, when endowed with regulatory functions over specialized fields, can exercise quasi-judicial powers over matters falling within their technical expertise and regulatory domain. The dispute involving the application of Clause 17 and the consequent rescission by Antipolo Realty was precisely within the NHA’s competence to ensure compliance with PD 957’s protective objectives. The Court found no grave abuse of discretion in the NHA’s factual determination and its order for reinstatement under equitable terms, which recognized Yuson’s right to suspend payments under the contract and prevented forfeiture arising from Antipolo Realty’s initial default.