Solid Homes, Inc. vs. Payawal

Exclusive jurisdiction over claims filed by subdivision lot or condominium unit buyers against project owners, developers, dealers, brokers, or salesmen—including claims for refund, specific performance of contractual and statutory obligations, damages, and attorney's fees—is vested in the National Housing Authority (now the Housing and Land Use Regulatory Board) under PD No. 1344, a special law that prevails over the general jurisdiction of Regional Trial Courts under BP No. 129 regardless of the dates of their enactment.

Teresita Payawal contracted to purchase a subdivision lot in Marikina from Solid Homes, Inc., a real estate developer. The regulatory framework governing the real estate trade and the rights of subdivision lot buyers was established by PD No. 957, issued in 1975, which initially vested in the National Housing Authority the power to regulate the real estate business. This regulatory function was later transferred to the Human Settlements Regulatory Commission by Executive Order No. 648 (February 7, 1981), which was renamed the Housing and Land Use Regulatory Board by Executive Order No. 90 (December 17, 1986). PD No. 1344, issued in 1978, expressly granted the National Housing Authority exclusive jurisdiction over certain classes of cases involving subdivision lot and condominium unit buyers. BP No. 129, promulgated in 1981, reorganized the judiciary and conferred original jurisdiction on Regional Trial Courts over civil actions involving real property and claims exceeding ₱20,000.00.

On June 9, 1975, Teresita Payawal contracted to purchase from Solid Homes, Inc. a subdivision lot in Marikina for the agreed price of ₱28,080.00. By September 10, 1981, she had paid the developer a total of ₱38,949.87 in monthly installments and interest. Solid Homes subsequently executed a deed of sale over the land but failed to deliver the corresponding certificate of title despite repeated demands from Payawal. It later appeared that the developer had mortgaged the property in bad faith to a financing company.

On August 31, 1982, Payawal filed a complaint against Solid Homes before the Regional Trial Court of Quezon City, docketed as Civil Case No. Q-36119. She sought delivery of the title to the lot or, alternatively, the return of all amounts paid plus interest, as well as moral and exemplary damages, attorney's fees, and costs. Solid Homes moved to dismiss the complaint on the ground that the court lacked jurisdiction, asserting that jurisdiction was vested exclusively in the National Housing Authority under PD No. 957. The motion was denied, and the defendant repleaded the jurisdictional objection in its answer, citing Section 3 of the decree.

After trial, the RTC rendered judgment in favor of Payawal, ordering Solid Homes to deliver the title to the land or, failing this, to refund ₱38,949.87 plus interest from 1975 until full payment. The court also awarded ₱5,000.00 moral damages, ₱5,000.00 exemplary damages, ₱10,000.00 attorney's fees, and costs. Solid Homes appealed to the Court of Appeals, which affirmed the RTC decision and reproved the developer for its dilatory tactics and for collecting an additional ₱1,238.47 from Payawal purportedly for realty taxes and registration expenses despite its inability to deliver title. The appellate court sustained the trial court's jurisdiction by reference to Section 41 of PD No. 957, which provides that the rights and remedies in the decree are in addition to those available under existing laws. The petitioner elevated the case to the Supreme Court on the jurisdictional issue, which it had consistently raised from the motion to dismiss through the answer and on appeal.

• Jurisdiction: Petitioner maintained that the Regional Trial Court had no jurisdiction over the complaint, exclusive jurisdiction being vested in the National Housing Authority under PD No. 957 and PD No. 1344, the latter decree expressly providing that the NHA shall have "exclusive jurisdiction" to hear and decide cases involving unsound real estate business practices, claims for refund and any other claims filed by subdivision lot buyers against developers, and cases involving specific performance of contractual and statutory obligations filed by buyers against owners, developers, dealers, brokers, or salesmen.
• Nullity of RTC Proceedings: Petitioner argued that the trial court's decision was null and void ab initio for having been rendered without jurisdiction, and that the proceedings should be struck down notwithstanding the delay a remand would entail.

• Jurisdiction under BP No. 129: Respondent contended that BP No. 129 confers jurisdiction on Regional Trial Courts over civil actions involving title to or possession of real property and over claims exceeding ₱20,000.00, and that this law should control as the later enactment, having been promulgated in 1981 after PD No. 957 (1975) and PD No. 1344 (1978).
• Section 41 of PD No. 957 as Concurrent Jurisdiction: Respondent argued that Section 41 of PD No. 957, providing that the rights and remedies in the decree are in addition to those available under existing laws, sustained the trial court's jurisdiction, its "clear and unambiguous tenor" undermining the petitioner's position.
• Damages Beyond Administrative Competence: Respondent brushed aside the opinion of the Secretary of Justice that the NHA had competence to award damages, treating it as impinging on the authority of the courts of justice.

• Jurisdiction: Whether the Regional Trial Court or the National Housing Authority (now the Housing and Land Use Regulatory Board) has exclusive jurisdiction over a complaint filed by a subdivision lot buyer against a developer for delivery of title, refund, and damages.
• Statutory Construction: Whether BP No. 129, as the later enactment, prevails over PD No. 1344 in determining jurisdiction, or whether the special law prevails regardless of dates of enactment.
• Section 41 of PD No. 957: Whether Section 41 of PD No. 957 vests concurrent jurisdiction in the regular courts alongside the administrative body.
• Authority to Award Damages: Whether the National Housing Authority has the competence to award damages and attorney's fees in cases falling under its exclusive jurisdiction.

• Jurisdiction: No. The Regional Trial Court had no jurisdiction; exclusive jurisdiction was vested in the National Housing Authority (now the Housing and Land Use Regulatory Board) under Section 1 of PD No. 1344, which expressly confers "exclusive jurisdiction" over claims filed by subdivision lot buyers against developers, including claims for refund, specific performance, and damages.
• Statutory Construction: No. BP No. 129 does not prevail over PD No. 1344. The familiar canon that a special law prevails over a general law regardless of the dates of their enactment controls; BP No. 129 is the general law and PD No. 1344 the special law.
• Section 41 of PD No. 957: No. Section 41 does not vest concurrent jurisdiction in the regular courts. Its purpose is merely to reserve to the aggrieved party such other remedies as may be provided by existing law, such as criminal prosecution under the Revised Penal Code; grants of jurisdictional power are not to be lightly inferred or merely implied.
• Authority to Award Damages: Yes. The competence to award damages is part of the exclusive power conferred upon the administrative body by PD No. 1344 to hear and decide "claims involving refund and any other claims," a phrase sufficiently broad to include all claims incidental to or a necessary consequence of the claims specifically enumerated.

• Jurisdiction: Section 1 of PD No. 1344 expressly grants the National Housing Authority "exclusive jurisdiction" to hear and decide three categories of cases: (A) unsound real estate business practices; (B) claims involving refund and any other claims filed by subdivision lot or condominium unit buyers against the project owner, developer, dealer, broker, or salesman; and (C) cases involving specific performance of contractual and statutory obligations filed by buyers against such parties. The complaint filed by Payawal—seeking delivery of title or refund, plus damages—falls squarely within these categories. The language of the section, particularly the phrase "exclusive jurisdiction," leaves no room for doubt that jurisdiction vested in the NHA, not the RTC. Under E.O. No. 648, the regulatory functions of the NHA were transferred to the Human Settlements Regulatory Commission, later renamed the Housing and Land Use Regulatory Board by E.O. No. 90.

• Statutory Construction: The private respondent's argument that BP No. 129 should control as the later enactment was rejected under the established canon that in case of conflict between a general law and a special law, the latter must prevail regardless of the dates of their enactment. The special law is considered as remaining an exception to the general law, whether the special law was passed before or after the general act. BP No. 129 is the general law; PD No. 1344 is the special law. Accordingly, the special law prevails notwithstanding that BP No. 129 was promulgated later.

• Section 41 of PD No. 957: The Court declined to read Section 41 as vesting concurrent jurisdiction in the regular courts, because grants of power are not to be lightly inferred or merely implied. The provision's sole purpose is to reserve to the aggrieved party other remedies available under existing law, such as criminal prosecution under the Revised Penal Code. It does not operate as a concurrent jurisdictional grant that would override the exclusive jurisdiction expressly conferred by PD No. 1344.

• Authority to Award Damages: The phrase "any other claims" in Section 1(B) of PD No. 1344 is sufficiently broad to include claims for damages and attorney's fees that are a necessary consequence of an adjudication of liability for non-performance of contractual or statutory obligations. The Secretary of Justice's opinion on this point was adopted. A strict construction denying the administrative body authority to adjudicate claims for damages and attorney's fees would result in multiplicity of suits, forcing a buyer who wins before the Board to litigate separately in regular courts for damages—a situation not contemplated by the law. Statutes conferring powers on administrative agencies must be liberally construed to enable them to discharge their assigned duties in accordance with legislative purpose. In Antipolo Realty Corporation vs. National Housing Authority, the Court had already sustained the competence of the administrative body to determine the rights of parties under a contract to sell a subdivision lot.

• Special Law Prevails Over General Law — In case of conflict between a general law and a special law, the latter must prevail regardless of the dates of their enactment. The special law is considered as remaining an exception to the general law, whether the special statute was passed before or after the general act, unless the general act expressly or by necessary implication repeals the special law. Applied here: BP No. 129 (general law on RTC jurisdiction) yielded to PD No. 1344 (special law on NHA jurisdiction over subdivision buyer claims).

• Exclusive Jurisdiction of Administrative Bodies Over Specialized Claims — Where a statute expressly confers "exclusive jurisdiction" on an administrative body over a defined category of cases, regular courts cannot assume jurisdiction over those cases even if their general jurisdiction statute would otherwise encompass the subject matter. The grant of exclusive jurisdiction to the NHA (now HLURB) under PD No. 1344 over claims by subdivision lot and condominium unit buyers against developers precluded RTC jurisdiction.

• Liberal Construction of Statutes Conferring Powers on Administrative Agencies — Statutes conferring powers on administrative agencies must be liberally construed to enable them to discharge their assigned duties in accordance with the legislative purpose. Applied to construe the phrase "any other claims" in PD No. 1344 as encompassing damages and attorney's fees incidental to the principal claims.

• Nullity of Judgments Rendered Without Jurisdiction — Any decision rendered without jurisdiction is a total nullity and may be struck down at any time, even on appeal before the Supreme Court. The only exception is where the party raising the issue is barred by estoppel, which did not apply here because the petitioner raised the jurisdictional objection from the earliest stage— the motion to dismiss—and consistently maintained it through the answer and on appeal.

• "The fact that one law is special and the other general creates a presumption that the special act is to be considered as remaining an exception of the general act, one as a general law of the land and the other as the law of the particular case." — This passage articulates the controlling canon of statutory construction that resolved the jurisdictional conflict between BP No. 129 and PD No. 1344, establishing that the special law on NHA jurisdiction prevails over the general judiciary reorganization law.

• "The language of this section, especially the italicized portions, leaves no room for doubt that 'exclusive jurisdiction' over the case between the petitioner and the private respondent is vested not in the Regional Trial Court but in the National Housing Authority." — This is the ratio decidendi on the jurisdictional issue, resting on the express statutory language of Section 1 of PD No. 1344.

• "We do not read that provision as vesting concurrent jurisdiction on the Regional Trial Court and the Board over the complaint mentioned in PD No. 1344 if only because grants of power are not to be lightly inferred or merely implied." — This passage defines the narrow scope of Section 41 of PD No. 957 and establishes the principle that jurisdictional grants must be express, not implied.

• "It is settled that any decision rendered without jurisdiction is a total nullity and may be struck down at any time, even on appeal before this Court." — This states the doctrine on nullity of judgments rendered without jurisdiction and the exception of estoppel, justifying the remand despite the delay it would entail.

• Manila Railroad Co. vs. Rafferty, 40 Phil. 224 (1919) — Cited as authority for the canon that a special law is considered as remaining an exception to a general law.
• Butuan Sawmill, Inc. vs. City of Butuan, 16 SCRA 758 — Cited in support of the special-law-over-general-law principle.
• Antipolo Realty Corporation vs. National Housing Authority, 153 SCRA 399 — Followed; the Court had previously sustained the competence of the NHA to determine the rights of parties under a contract to sell a subdivision lot in the exercise of its exclusive jurisdiction under PD No. 957 and PD No. 1344.
• Tropical Homes vs. National Housing Authority, 152 SCRA 54 — Distinguished; the Court there upheld the constitutionality of the appeal procedure under PD No. 1344 but did not rule on the exclusive jurisdiction question, which was decided for the first time in the present case.
• Tijam vs. Sibonghanoy, 23 SCRA 29 — Cited for the exception of estoppel to the rule that jurisdiction may be raised at any stage; the Court found estoppel inapplicable because the petitioner had consistently raised the jurisdictional objection from the outset.
• Trinidad vs. Yatco, 1 SCRA 866 — Cited for the doctrine that decisions rendered without jurisdiction are total nullities that may be struck down at any time.

• Section 1, PD No. 1344 — Grants the National Housing Authority "exclusive jurisdiction" to hear and decide cases involving unsound real estate business practices, claims for refund and any other claims filed by subdivision lot or condominium unit buyers against developers, and cases involving specific performance of contractual and statutory obligations filed by buyers against owners, developers, dealers, brokers, or salesmen. This was the controlling provision establishing the NHA's exclusive jurisdiction over Payawal's complaint.
• Section 3, PD No. 957 — Provides that the National Housing Authority shall have exclusive jurisdiction to regulate the real estate trade and business. Petitioner cited this in its motion to dismiss and answer.
• Section 41, PD No. 957 — Provides that the rights and remedies in the decree are in addition to any and all other rights and remedies available under existing laws. The Court construed this as merely reserving other remedies (e.g., criminal prosecution), not as vesting concurrent jurisdiction in regular courts.
• Section 19, BP No. 129 — Confers exclusive original jurisdiction on Regional Trial Courts over civil actions incapable of pecuniary estimation, actions involving title to or possession of real property, and claims exceeding ₱20,000.00. Held to be the general law yielding to the special law (PD No. 1344).
• Article 2208, Civil Code — Governs recovery of attorney's fees, including when exemplary damages are awarded and when the defendant acted in gross and evident bad faith in refusing to satisfy the plaintiff's plainly valid, just, and demandable claim. Cited to support the NHA's competence to award attorney's fees.
• E.O. No. 648 (Feb. 7, 1981) — Transferred the regulatory functions of the NHA under PD Nos. 957, 1216, 1344, and related laws to the Human Settlements Regulatory Commission.
• E.O. No. 90 (Dec. 17, 1986) — Renamed the Human Settlements Regulatory Commission as the Housing and Land Use Regulatory Board.

Narvasa, Gancayco, Griño-Aquino, and Medialdea, JJ., concurred.