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.