C.T. TORRES ENTERPRISES, INC., vs. HON. ROMEO J. HIBIONADA, EFREN DIONGON, and PLEASANTVILLE DEVELOPMENT CORPORATION.
- G.R. Number: G.R. No. 80916
- Promulgated: 1976-07-12
Doctrine
A statute may vest exclusive original jurisdiction in an administrative agency over matters within its special expertise; administrative agencies may be vested with quasi-judicial powers.
A motion for reconsideration before the trial court may be dispensed with when the issue presented is a question of law, allowing direct recourse to this Court.
When jurisdiction is exclusively vested in an administrative agency, civil actions improperly filed in regular courts must be dismissed without prejudice to filing before the proper agency.
Facts
Petitioner, as agent of Pleasantville Development Corporation, sold a subdivision lot on installment to Efren Diongon; after installments were completed, Diongon demanded the certificate of title which was not delivered and he sued for specific performance and damages in the RTC (Civil Case No. 3514).
Both defendants filed answers with cross-claims and counterclaims; pre-trial and trial briefs were conducted (case proceedings at the RTC).
The same jurisdictional issue decided in a prior ruling was raised here and the Court applied the same ruling.
Issues
Whether the Regional Trial Court had jurisdiction over the complaint for specific performance and damages involving the sale of a subdivision lot.
Whether a motion for reconsideration in the trial court was a necessary antecedent before bringing the jurisdictional question to this Court.
Ruling
The Court held the complaint was improperly filed in the RTC because jurisdiction over the case was exclusively vested in the Housing and Land Use Regulatory Board (HLURB).
The Court ruled that the order denying the motion to dismiss was immediately challengeable here because the issue was one of law and thus a motion for reconsideration was not indispensable.
Disposition: Petition granted; the questioned Order of 17 September 1987 is set aside and Civil Case No. 3514 in the RTC of Negros Occidental is dismissed without prejudice to filing the proper complaint with the HLURB. No costs.
Keywords
G.R. No. 80916, Solid Homes v. Payawal, jurisdiction, specific performance, damages, Regional Trial Court, Housing and Land Use Regulatory Board, Executive Order No. 90, Batas Pambansa Blg. 129, P.D. No. 1344, P.D. No. 957, The Subdivision and Condominium Buyers' Protective Decree, National Housing Authority, exclusive authority to regulate the real estate trade and business, unsound real estate business practices, claims involving refund, cases involving specific performance of contractual and statutory obligations, E.O. No. 648, Human Settlements Regulatory Commission, quasi-judicial function