SOLID HOMES, INC. v. PAYAWAL 6.
After trial, judgment was rendered in favor of Payawal and petitioner was
ordered to deliver to her the title to the land or, failing this, to refund to her
August 29, 1989 | Cruz, J. | Implications the sum of P38,949.87 plus interest from 1975 and until the full amount was
paid.
PETITIONER: Solid Homes, Inc.
RESPONDENTS: Teresita Payawal and Court of Appeals 7. Petitioner appealed but the decision was affirmed by Court of Appeals,
which also berated its obvious efforts to evade a legitimate obligation,
including its dilatory tactics during the trial.
8. In holding that the trial court had jurisdiction, the CA referred to Section 41
SUMMARY: Payawal filed a complaint against petitioner before the Regional
Trial Court alleging that they contracted to sell her subdivision lot in Marikina. of PD 957 and declared that “its clear and unambiguous tenor undermined
petitioner’s pretension that the court a quo was bereft of jurisdiction”
Subsequently, petitioner executed a deed of sale but failed to deliver the
corresponding certificate title despite of repeated demands by Payawal because
defendant had mortgaged the property in bad faith to a financing company.
ISSUE: whether or not the RTC had jurisdiction over the subject matter – NO. The
Petitioner moved to dismiss the complaint on the ground that the court had no applicable law is Section 1 of PD 957 and the language of this section, especially the
jurisdiction, this being rested in the National Housing Authority under PD 597. The italicized portions, leaves no room for doubt that “exclusive jurisdiction” over the
motion was denied, hence, the petition to reverse said decision of the Court of case between the petitioner and Payawal is vested not in the RTC but in the NHA
Appeals in sustaining the jurisdiction of the Regional Trial Court was submitted by
petitioner to the Supreme Court.
RULING: wherefore, the challenged decision of CA is reversed and the decision of
DOCTRINE: In case of conflict between a general law and a special law, the latter the RTC of Quezon City is set aside, without prejudice to the filing of the
must prevail regardless of the dates of their enactment. appropriate complaint before the NHA (now Housing and Land Use Regulatory
Board or HLURB)
FACTS: RATIO:
1. The complaint was filed on 31 August 1982 by Teresita Payawal against 1. Payawal contends that the applicable law BP 129, which confers on RTC
Solid Homes, Inc. before the RTC of Quezon City, alleging that petitioner jurisdiction to hear and decided cases mentioned in Section 19, and stresses
contracted to sell to her a subdivision lot in Marikina on 9 June 1975 for that BP 129 should control as the later enactment, having been promulgated
the agreed price of P28, 080.00, and that by 10 September 1981, she had in 1981, after PD 957 was issued in 1975 and PD 1344 in 1978.
already paid petitioner the total amount of P38, 949.87 in monthly 2. This construction must yield to the familiar canon that in case of
installments and interests. conflict between a general law and a special law, the latter must prevail
2. Petitioner subsequently executed a deed of sale over the land but failed to regardless of the dates of their enactment. It is obvious that the general
deliver the corresponding certificate of title despite her repeated demands law is BP 129 and PD 1344 (amending PD 957) is the special law.
because it had mortgaged the property in bad faith to a financing company. 3. The argument that the trial court could also assume jurisdiction because of
3. Payawal asked for delivery of the title of the lot or, alternatively, the return Section 41 of PD 957 is also unacceptable as the Higher Court do not
of all the amounts paid by her plus interest read that provision as vesting concurrent jurisdiction on the RTC and
4. Petitioner moved to dismiss the complaint on the ground that the court had the Board over the complaint mentioned in PD 1344 if only because
no jurisdiction, this being vested in the National Housing Authority under grants of power are not to be lightly inferred or merely implied.
PD 957, but the motion was denied. 4. Statutes conferring powers on their administrative agencies must be
5. Petitioner repleaded the objection in its answer, citing Section 3 of the said liberally construed to enable them to discharge their assigned duties in
decree providing that “the National Housing Authority shall have exclusive accordance with the legislative purpose. In Antipolo Realty Corp. v. NHA,
jurisdiction to regulate the real estate trade and business in accordance with the Court sustained the competence of NHA, in the exercise of the exclusive
the provisions of this Decree.” jurisdiction vested in it by PD 957 and PD 1344, to determine the rights of
the parties under a contract to sell a subdivision lot.
