You are on page 1of 8

ADMINISTATIVE LAW CASES Atty.

Gallant Soriano

G.R. No. 84811 August 29, 1989


SOLID HOMES, INC., petitioner, vs.
TERESITA PAYAWAL and COURT OF
APPEALS, respondents.

FACTS:
The complaint was filed by Teresita Payawal against
Solid Homes, Inc. before the Regional Trial Court of
Quezon City. Teresite, alleged that Solid Homes sold to
her a subdivision lot in Marikina on June 9, 1975, for P
28,080.00, and that by September 10, 1981, she had
already paid the full amount of P 38,949.87 including
interests. Solid Homes subsequently executed a deed
of sale over the land but failed to deliver the
corresponding certificate of title because it was later
discovered that Solid Homes had mortgaged the
property in bad faith to a financing company. The
plaintiff asked for delivery of the title to the lot or,
alternatively, the return of all the amounts paid by her
plus interest. She also claimed moral and exemplary
damages, attorney's fees and the costs of the suit.
Solid Homes moved to dismiss the complaint on the
ground that the court had no jurisdiction, this being
vested in the National Housing Authority under PD No.
957.
ISSUE:

WON the National Housing


jurisdiction to decide the case.

Authority

has

the

HELD:
Yes. The applicable law is PD No. 957, 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. In the exercise of its function to
regulate the real estate trade and shall
have exclusive jurisdiction to hear and
decide cases of the following nature:
A. Unsound
practices;

real

estate

business

B. Claims involving refund and any


other claims filed by subdivision lot or
condominium unit buyer against the
project owner, developer, dealer,
broker or salesman; and
C.
Cases involving
specific
performance
of
contractuala
statutory obligations filed by buyers
of subdivision lot or condominium
unit against the owner, developer,
dealer,
broker
or
salesman.
(Emphasis supplied.)

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

This construction must yield to the familiar canon


that in case of conflict between a general law and a
special law, the latter must prevail regardless of the
dates of their enactment. It is obvious that the general
law in this case is BP No. 129(Jurisdiction of courts in
Civil Cases) and PD No. 1344 (Empowering the NHA)
the special law.
As a result of the growing complexity of the
modern society, it has become necessary to create
more and more administrative bodies to help in the
regulation of its ramified activities. Specialized in the
particular fields assigned to them, they can deal with CHRISTIAN GENERAL ASSEMBLY, INC. v. IGNACIO
the problems thereof with more expertise and dispatch G.R. No. 164789 | August 27, 2009
than can be expected from the legislature or the courts
of justice. This is the reason for the increasing vesture
The extent to which an administrative entity may exercise judicial or
of quasi-legislative and quasi-judicial powers in what is
quasi-judicial powers depends largely, if not wholly on the
now not unreasonably called the fourth department of
provisions of the statute creating or empowering such agency. In the
exercise of such powers, the agency concerned must commonly
the government.
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

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

mutually agreed to amend the Contract to Sell to Instead of filing an answer, the respondents filed a
extend the payment period from three to five years.
motion to dismiss asserting that the RTC had no
jurisdiction over the case. The respondents claimed
According to CGA, it religiously paid the monthly
that the case falls within the exclusive jurisdiction of
installments until its administrative pastor discovered
that the title covering the subject property was actually the HLURB since it involved the sale of a subdivision
part of two consolidated lots (Lots 2-F and 2-G Bsd-04- lot. CGA opposed the motion to dismiss, claiming that
000829 [OLT]) that the respondents had acquired from the action is for rescission of contract, not specific
Nicanor Adriano (Adriano) and Ceferino Sison (Sison), performance, and is not among the actions within the
respectively. Adriano and Sison were former tenant- exclusive jurisdiction of the HLURB.
beneficiaries of Purificacion S. Imperial (Imperial)
whose subject property had been placed under ISSUE
Presidential Decree (PD) No. 27s Operation Land Which of the two the regular court or the HLURB has
Transfer. According to CGA, Imperial applied for the exclusive jurisdiction over CGAs action for rescission
retention of five hectares of her land under Republic and damages.
Act No. 6657, which the Department of Agrarian Reform
(DAR) granted. The DAR Order authorized Imperial to HELD
retain the farm lots previously awarded to the tenant- HLURB has exclusive jurisdiction over CGAs action for
beneficiaries, including Lot 2-F previously awarded to rescission and damages.
Adriano, and Lot 2-G Bsd-04-000829 awarded to Sison.
Rationale for HLURBs extensive quasi-judicial
Understandably aggrieved after discovering these powers
circumstances, CGA filed a complaint against the
respondents before the RTC. CGA claimed that the The surge in the real estate business in the country
brought with it an increasing number of cases between
respondents fraudulently concealed the fact that the
subdivision owners/developers and lot buyers on the
subject property was part of a property under litigation; issue of the extent of the HLURBs exclusive
thus, the Contract to Sell was a rescissible contract jurisdiction. The courts have consistently ruled that the
under Article 1381 of the Civil Code. CGA asked the HLURB has exclusive jurisdiction over complaints
trial court to rescind the contract; order the arising from contracts between the subdivision
respondents to return the amounts already paid; and developer and the lot buyer or those aimed at
compelling the subdivision developer to comply with its
award actual, moral and exemplary damages,
contractual and statutory obligations to make the
attorneys fees and litigation expenses.
subdivision a better place to live in.
Generally, the extent to which an administrative
agency may exercise its powers depends largely, if not

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

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 quasi-judicial 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.

Dadubo v. CSC, G.R. No. 106498, June 28, 1993


Facts:
Dadubo and Cidro of the DBP Borongan branch bank
were administratively charged with conduct prejudicial
to best interest of the service, based on allegations on

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

the unposted withdrawal of P60,000 from the savings


accounts of the Tius. DBP found Dadubo guilty of
dishonesty for embezzlement of bank funds. She was
penalized with dismissal and fined an amount equal to
1 month basic salary. However, Civil Service
Commission reversed the DBP findings and reduced
Dadubos penalty to suspension for 6 months. DBP
moved for reconsideration and CSC affirmed the earlier
findings as to Dadubos guilt. Dadubo brought the
present case to SC on certiorari, claiming that CSC
failed to comply w/ constitutional requirement to state
clearly and distinctly the facts and the law on which the
decision is based.
Issue: Whether or not there is violation of the
administrative due process
Held:

The parties are both forest concessionaries whose


licensed areas are adjacent to each other. Since the
concessions of petitioner and respondent are adjacent
to each other, they have a common boundary. Reports
of encroachment by both parties on each others
concessions triggered a survey to establish the
common boundary of the respective concession areas
and was held that the claim of Ago Timber Corporation
runs counter to the intentions of the Office granting the
Timber License Agreement to Lianga Bay Logging. Ago
Timber appealed to Department of Agriculture and
Natural Resources and set aside the appealed decision
of the Director of Forestry and ruled in favor of Ago.
Lianga Bay Logging elevated the case to office of
President and ruling of Agriculture and Natural
Resources was affirmed. On Motion for Recon, decision
was reversed and reinstated decision of Director of
Forestry. A civil action was instituted by Ago Timber to
determine the correct boundary line of license timber
areas. TRO was set in place. Lianga brought the case to
SC on certiorari.

Compliance with the constitutional requirement to state


clearly and distinctly the facts and the law on which a
decision is based on applies only to courts of justice
and not to administrative bodies like the Civil Service
Issue: WON respondent court has jurisdiction over the
Commission.
administrative case
In any event, there was an earlier statement of the
facts and the law involved in the decision rendered by Held:
the MSPB dated February 28, 1990, which affirmed
DBP's decision to dismiss the petitioner. In both Respondent Judge erred in taking cognizance of the
decisions, the facts and the law on which they were complaint filed by respondent Ago, asking for the
based were clearly and distinctly stated.
determination anew of the correct boundary line of its
Lianga Bay Logging, Co., Inc. v. Enage, G.R. No. licensed timber area, for the same issue had already
L-30637, July 16, 1987
been determined by the Director of Forestry, the
Secretary of Agriculture and Natural Resources and the
Facts:
Office of the President, administrative officials under

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

whose jurisdictions the matter properly belongs.


Section 1816 of the Revised Administrative Code vests
in the Bureau of Forestry, the jurisdiction and authority
over the demarcation, protection, management,
reproduction, reforestation, occupancy, and use of all
public forests and forest reserves and over the granting
of licenses for game and fish, and for the taking of
forest products, including stone and earth therefrom.
The Secretary of Agriculture and Natural Resources, as
department head, may repeal or modify the decision of
the Director of Forestry when advisable in the public
interests, whose decision is in turn appealable to the
Office of the President. For the respondent court to
consider and weigh again the evidence already
presented and passed upon by said officials would be
to allow it to substitute its judgment for that of said
officials who are in a better position to consider and
weigh the same in the light of the authority specifically
vested in them by law. it is a well-settled doctrine that
the courts of justice will generally not interfere with
purely administrative matters which are addressed to
the sound discretion of government agencies and their
expertise unless there is a clear showing that the latter
acted arbitrarily or with grave abuse of discretion or
when they have acted in a capricious and whimsical
manner such that their action may amount to an
excess or lack of jurisdiction.

Luzon Development Bank vs Association of Luzon


Development Bank Employees (249 SCRA 162)
Facts:
From a submission agreement of the LDB and ALDBE
arose an arbitration case to resolve the issue whether
or not the company violated the CBA provision and the
Memorandum Agreement. The parties agreed to submit
their respective position papers.
Atty Ester Garcia, Voluntary Arbitrator
-

Received ALDBs position paper while LDB failed


to do the same. Hence, the former rendered a
decision that the bank has not adhered to the
CBA nor Memorandum Agreement. Petition for
certiorari and prohibition seeking to set aside the
decision of the VA and to prohibit her from
enforcing the same

Issues: WON a voluntary arbiters decision is


appealable to the Court of Appeals and not to the
Supreme Court.
Held:
Yes, the court can refer the case to the CA. Voluntary
arbiter performs state functions pursuant to
governmental power delegated to him under the Labor
Code and Section 9 of BP Blg. 129(as amended by RA
7902) stating CA shall exercise exclusive appellate

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

jurisdiction over all final judgments, resolutions, orders, and related facilities owned by Maria Cristina Fertilizer
Corporation (MCFC), LOI No. 1277, also dated
or awards or RTC and quasi-judicial agencies,
November 16, 1982, was issued directing the NSC to
instrumentalities, including SEC and CSC.
negotiate with the owners of MCFC, for and on behalf
of the Government, for the compensation of MCFCs
present occupancy rights on the subject land.
Iron and Steel Authority vs CA 249 SCRA 538

Negotiations between NSC and MCFC failed.

ISSUE: WON the Government is entitled to be


substituted for ISA in view of the expiration of ISAs
Petitioner ISA was created by PD No. 272 in order, term.
generally, to develop and promote the iron and steel
Held: Yes
industry.
.
PD No. 272 initially created ISA for a term of 5 years Clearly, ISA was vested with some of the powers or
normally
associated
with
juridical
counting from August 9, 1973. When ISAs original term attributed
personality.
There
is,
however,
no
provision
in
PD No.
expired on October 10, 1978, its term was extended for
another 10 years by EO No. 555 dated August 31, 272 recognizing ISA as possessing general or
comprehensive juridical personality separate and
1979.
distinct from that of the government. The ISA in fact
The National Steel Corporation (NSC) then a wholly appears to the Court to be a non-incorporated agency
owned subsidiary of the National Development or instrumentality of the RP, or more precisely of the
Corporation which is itself an entity wholly owned by Government of the Philippines. It is common knowledge
the National Government, embarked on an expansion that other agencies or instrumentalities of the
program embracing, among other things, the Government of the Republic are cast in corporate form,
construction of an integrated steel mill in Iligan City. that is to say, are incorporated agencies or
The construction of such steel mill was considered a instrumentalities, sometimes with and at other times
priority and major industrial project of the government. without capital stock, and accordingly vested with a
Pursuant to the expansion program of the NSC, juridical personality distinct from the personality of the
Proclamation No. 2239 was issued by the President of Republic.
the Philippines on November 16, 1982 withdrawing
from sale or settlement a large tract of public land We consider that the ISA is properly regarded as an
located in Iligan City, and reserving that land for the agent or delegate of the RP. The Republic itself is a
body corporate and juridical person vested with the full
use and immediate occupancy of NSC.
Since certain portions of the aforesaid public land were panoply of powers and attributes which are
occupied by a non-operational chemical fertilizer plant compendiously described as legal personality.
FACTS:

ADMINISTATIVE LAW CASES Atty. Gallant Soriano

When the statutory term of non-incorporated agency


expires, the powers, duties and functions as well as the
assets and liabilities of that agency revert back to, and
are reassumed by the RP, in the absence of special
provisions of law specifying some other disposition
thereof, e.g., devolution or transmission of such
powers, duties and functions, etc. to some other
identified successor agency or instrumentality of the
RP.
When the expiring agency is an incorporated one, the
consequence of such expiry must be looked for, in the
first instance, in the charters and, by way of
supplementation, the provisions of the Corporation
Code. Since in the instant case, ISA is a nonincorporated agency or instrumentality of the Republic,
its powers, duties and functions, assets and liabilities
are properly regarded as folded back into the
Government and hence assumed once again by the
Republic, no special statutory provision having been
shown to have mandated succession thereto by some
other entity or agency of the Republic.

In the instant case, ISA substituted the expropriation


proceedings in its capacity as an agent or delegate or
representative of the Republic of the Philippines
pursuant to its authority under PD 272.
The principal or the real party in interest is thus the
Republic of the Philippines and not the NSC, even
though the latter may be an ultimate user of the
properties involved.
From the foregoing premises, it follows that the
Republic is entitled to be substituted in the
expropriation proceedings in lieu of ISA, the statutory
term of ISA having expired. Put a little differently, the
expiration of ISAs statutory term did not by itself
require or justify the dismissal of the eminent domain
proceedings.