CHRISTIAN GENERAL ASSEMBLY, INC. v.

IGNACIO
G.R. No. 164789 | August 27, 2009
The extent to which an administrative entity may exercise judicial or
quasi-judicial powers depends largely, if not wholly on the
provisions of the statute creating or empowering such agency. In the
exercise of such powers, the agency concerned must commonly
interpret and apply contracts and determine the rights of private
parties under such contracts. One thrust of the multiplication of
administrative agencies is that the interpretation of contracts and the
determination of private rights thereunder is no longer a uniquely
judicial function, exercisable only by our regular courts.

FACTS
CGA entered into a Contract to Sell a subdivision lot4 (subject property)
with the respondents the registered owners and developers of a housing
subdivision known as Villa Priscilla Subdivision located in Bulacan.
Under the Contract to Sell, CGA would pay P2,373,000.00 for the subject
property on installment basis; they were to pay a down payment of
P1,186,500, with the balance payable within three years. Subsequently, the
parties mutually agreed to amend the Contract to Sell to extend the
payment period from three to five years.
According to CGA, it religiously paid the monthly installments until its
administrative pastor discovered that the title covering the subject property
was actually part of two consolidated lots (Lots 2-F and 2-G Bsd-04000829 [OLT]) that the respondents had acquired from Nicanor Adriano
(Adriano) and Ceferino Sison (Sison), respectively. Adriano and Sison
were former tenant-beneficiaries of Purificacion S. Imperial (Imperial)
whose subject property had been placed under Presidential Decree (PD)
No. 27s Operation Land Transfer. According to CGA, Imperial applied
for the retention of five hectares of her land under Republic Act No. 6657,
which the Department of Agrarian Reform (DAR) granted. The DAR

Order authorized Imperial to retain the farm lots previously awarded to the
tenant-beneficiaries, including Lot 2-F previously awarded to Adriano, and
Lot 2-G Bsd-04-000829 awarded to Sison.
Understandably aggrieved after discovering these circumstances, CGA
filed a complaint against the respondents before the RTC. CGA claimed
that the respondents fraudulently concealed the fact that the subject
property was part of a property under litigation; thus, the Contract to Sell
was a rescissible contract under Article 1381 of the Civil Code. CGA
asked the trial court to rescind the contract; order the respondents to return
the amounts already paid; and award actual, moral and exemplary
damages, attorneys fees and litigation expenses.
Instead of filing an answer, the respondents filed a motion to dismiss
asserting that the RTC had no jurisdiction over the case. The respondents
claimed that the case falls within the exclusive jurisdiction of the HLURB
since it involved the sale of a subdivision lot. CGA opposed the motion to
dismiss, claiming that the action is for rescission of contract, not specific
performance, and is not among the actions within the exclusive jurisdiction
of the HLURB.
ISSUE
Which of the two the regular court or the HLURB has exclusive
jurisdiction over CGAs action for rescission and damages.
HELD
HLURB has exclusive jurisdiction over CGAs action for rescission and
damages.
Rationale for HLURBs extensive quasi-judicial powers
The surge in the real estate business in the country brought with it an
increasing number of cases between subdivision owners/developers and lot
buyers on the issue of the extent of the HLURBs exclusive jurisdiction.

The courts have consistently ruled that the HLURB has exclusive
jurisdiction over complaints arising from contracts between the
subdivision developer and the lot buyer or those aimed at compelling the
subdivision developer to comply with its contractual and statutory
obligations to make the subdivision a better place to live in.
Generally, the extent to which an administrative agency may exercise its
powers depends largely, if not wholly, on the provisions of the statute
creating or empowering such agency. Presidential Decree (P.D.) No. 1344,
"Empowering The National Housing Authority To Issue Writ Of
Execution In The Enforcement Of Its Decision Under Presidential Decree
No. 957," clarifies and spells out the quasi-judicial dimensions of the grant
of jurisdiction to the HLURB.
The provisions of PD 957 were intended to encompass all questions
regarding subdivisions and condominiums. The intention was aimed at
providing for an appropriate government agency, the HLURB, to which all
parties aggrieved in the implementation of provisions and the enforcement
of contractual rights with respect to said category of real estate may take
recourse. The business of developing subdivisions and corporations being
imbued with public interest and welfare, any question arising from the
exercise of that prerogative should be brought to the HLURB which has
the technical know-how on the matter. In the exercise of its powers, the
HLURB must commonly interpret and apply contracts and determine the
rights of private parties under such contracts. This ancillary power is no
longer a uniquely judicial function, exercisable only by the regular courts.
The argument that only courts of justice can adjudicate claims resoluble
under the provisions of the Civil Code is out of step with the fast-changing
times. There are hundreds of administrative bodies now performing this
function by virtue of a valid authorization from the legislature. This quasijudicial function, as it is called, is exercised by them as an incident of the
principal power entrusted to them of regulating certain activities falling
under their particular expertise. In this era of clogged court dockets, the
need for specialized administrative boards or commissions with the special

knowledge, experience and capability to hear and determine promptly

disputes on technical matters or essentially factual matters, subject to
judicial review in case of grave abuse of discretion, has become well nigh
indispensable.
In general, the quantum of judicial or quasi-judicial powers which an
administrative agency may exercise is defined in the enabling act of such
agency. In other words, the extent to which an administrative entity may
exercise such powers depends largely, if not wholly on the provisions of
the statute creating or empowering such agency. In the exercise of such
powers, the agency concerned must commonly interpret and apply
contracts and determine the rights of private parties under such contracts.
One thrust of the multiplication of administrative agencies is that the
interpretation of contracts and the determination of private rights
thereunder is no longer a uniquely judicial function, exercisable only by
our regular courts.