ANTIPOLO REALTY CORPORATION vs NATIONAL HOUSING AUTHORITY Case Digest

ANTIPOLO REALTY CORPORATION v. THE NATIONAL HOUSING AUTHORITY

G.R. No. L-50444 August 31, 19!
"ACTS# Jose Hernando acquired ownership over Lot. No. 15, Block IV of the onderosa
Hei!hts "u#division fro$ the petitioner %ntipolo &ealt' (orporation. )n *+ %u!ust 1,-., /r.
Hernando transferred his ri!hts over Lot No. 15 to private respondent Vir!ilio 0uson.
However, for failure of %ntipolo &ealt' to develop the su#division pro1ect, /r. 0uson paid onl'
the arreara!es pertainin! to the period up to, and includin!, the $onth of %u!ust 1,-* and
stopped all $onthl' install$ent pa'$ents fallin! due thereafter. )n )cto#er 1. 1,-2, the
president of %ntipolo &ealt' sent a notice to private respondent 0uson advisin! that the
required i$prove$ents in the su#division had alread' #een co$pleted, and requestin!
resu$ption of pa'$ent of the $onthl' install$ents on Lot No. 15.
/r. 0uson refused to pa' the "epte$#er 1,-*3)cto#er 1,-2 $onthl' install$ents #ut a!reed
to pa' the post )cto#er 1,-2 install$ents. %ntipolo &ealt' responded #' rescindin! the
(ontract to "ell, and clai$in! the forfeiture of all install$ent pa'$ents previousl' $ade #' /r.
0uson. /r. 0uson #rou!ht his dispute with %ntipolo &ealt' #efore pu#lic respondent NH%.
%fter hearin!, the NH% rendered a decision on , /arch 1,-+ orderin! the reinstate$ent of
the (ontract to "ell. %ntipolo &ealt' filed a /otion for &econsideration assertin! that the
1urisdiction to hear and decide /r. 0uson4s co$plaint was lod!ed in the re!ular courts, not in
the NH%.
5he $otion for reconsideration was denied #' respondent NH%, which sustained its
1urisdiction to hear and decide the 0uson co$plaint. Hence, this petition.
ISSUE# 6hether or not NH% has 1urisdiction over the present controvers'.
HEL$# NH% was upheld #' the "(.
It is #' now co$$onplace learnin! that $an' ad$inistrative a!encies e7ercise and perfor$
ad1udicator' powers and functions, thou!h to a li$ited e7tent onl'. Li$ited dele!ation of
1udicial or quasi31udicial authorit' to ad$inistrative a!encies is well reco!ni8ed in our
1urisdiction, #asicall' #ecause the need for special co$petence and e7perience has #een
reco!ni8ed as essential in the resolution of questions of co$ple7 or speciali8ed character and
#ecause of a co$panion reco!nition that the dockets of our re!ular courts have re$ained
crowded and clo!!ed. In !eneral the quantu$ of 1udicial or quasi31udicial powers which an
ad$inistrative a!enc' $a' e7ercise is defined in the ena#lin! act of such a!enc'. In other
words, the e7tent to which an ad$inistrative entit' $a' e7ercise such powers depends
lar!el', if not wholl', on the provisions of the statute creatin! or e$powerin! such a!enc'. In
the e7ercise of such powers, the a!enc' concerned $ust co$$onl' interpret and appl'
contracts and deter$ine the ri!hts of private parties under such contracts.
"ection 9 of residential :ecree No. ,5-, known as ;5he "u#division and (ondo$iniu$
Bu'ers4 :ecree;, states that National Housin! %uthorit'. < 5he National Housin! %uthorit'
shall have e7clusive 1urisdiction to re!ulate the real estate trade and #usiness in accordance
with the provisions of this decree. residential :ecree No. 19.., clarified and spelled out the
quasi31udicial di$ensions of the !rant of re!ulator' authorit' to the NH% in the followin!
$anner=
">(5I)N 1. In the e7ercise of its functions to re!ulate the real estate trade and #usiness and
in addition to its powers provided for in residential :ecree No. ,5-, the National Housin!
%uthorit' shall have e7clusive 1urisdiction to hear and decide cases of the followin! nature=
%. ?nsound real estate #usiness practices=
B. (lai$s involvin! refund and an' other clai$s filed #' su#3 division lot or condo$iniu$ unit
#u'er a!ainst the pro1ect owner, developer, dealer, #roker or sales$an@ and
(. (ases involvin! specific perfor$ance of contractual and statutor' o#li!ations filed #'
#u'ers of su#division lots or condo$iniu$ units a!ainst the owner, developer, dealer, #roker
or sales$an.
5he need for and therefore the scope of the re!ulator' authorit' thus lod!ed in the NH% are
indicated in the second and third prea$#ular para!raphs of the statute. 5here is no question
that under residential :ecree No. ,5-, the NH% was le!all' e$powered to deter$ine and
protect the ri!hts of contractin! parties under the law ad$inistered #' it and under the
respective a!ree$ents, as well as to ensure that their o#li!ations thereunder are faithfull'
perfor$ed.