Solid Homes v Teresita Payawal

Facts:

On August 31, 1982 Teresita Payawal filed a complaint against Solid Homes Inc., before the Regional

Trial Court alleging that they contracted to sell her subdivision lot in Marikina on June 9, 1975.

Subsequently Solid Homes Inc. 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.

Thereafter, Solid Homes Inc moved to dismiss the complaint on the ground that the court had no

jurisdiction this being rested in the National Housing Authority under PD no. 597. The motion was

denied, hence, the petition to reverse said decision of the Court of Appeals in sustaining the jurisdiction

of the Regional Trial Court was submitted by Solid Homes Inc. to the Supreme Court.

Issue:

Whether or not the trial court had jurisdiction over cases involving claims, refund and any other claims

filed by subdivision lot or condominium unit buyers against the project owner,developer,dealer,broker

or salesman?

Held:

The Supreme Court ruled that the applicable law is PD No. 957. The National Housing Authority has

the jurisdiction.

As amended by PD No 1344 entitled “Empowering the National Housing Authority to issue writs of

execution in the enforcement of its decisions under Presidential Decree No 957” Section 1 provides, in

the exercise of its function to regulate the real estate trade and business and in addition to its powers

provided for in PD No 957 that the National Housing Authority shall have exclusive jurisdiction to

hear and decide cases of the following nature: a) unsound real estate business practices, b) claims

involving refund and any other claims filed by subdivision lot owners or condo unit buyers against

project owner, developer, dealer, broker, or salesman and, c) cases involving specific performance of

contractual statutory obligations filed by buyers of subdivision lot or condominium unit against the

owner, developer, dealer, broker or salesman.

The challenged decision of the respondent court was reversed and the decision of RTC is Set Aside

without prejudice to the filing of the appropriate complaint before the HLURB.