Administrative Law

Arellano University School of Law

aiza ebina/2015

Antipolo Realty Corporation vs National Housing Authority

153 SCRA 399
Extent of Judicial or Quasi-Judicial Powers of Administrative Agencies
FACTS: Jose Hernando acquired prospective and beneficial ownership over Lot. No. 15, Block IV of the
Ponderosa Heights Subdivision in Antipolo, Rizal, from the petitioner Antipolo Realty Corporation under a
Contract to Sell. On 28 August 1974, Hernando transferred his rights over the said lot to private
respondent Virgilio Yuson, embodied in a Deed of Assignment and Substitution of Obligor. However, for
failure of Antipolo Realty to develop the subdivision project in accordance with its undertaking under
Clause 17 of the Contract to Sell (subdivision beautification), Mr. Yuson paid only the arrearages pertaining
to the period up to, and including, the month of August 1972 and stopped all monthly installment
payments falling due thereafter.
On 14 October 1976, the president of Antipolo Realty sent a notice to private respondent Yuson advising
that the required improvements in the subdivision had already been completed, and requesting
resumption of payment of the monthly installments on Lot No. 15. For his part, Mr. Yuson replied that he
would conform with the request as soon as he was able to verify the truth of the representation in the
notice. In a second letter dated 27 November 1976, Antipolo Realty reiterated its request, citing the
decision rendered by the National Housing Authority (NHA) on 25 October 1976 in Case No. 252 (entitled
"Jose B. Viado Jr., complainant vs. Conrado S. Reyes, respondent") declaring Antipolo Realty to have
"substantially complied with its commitment to the lot buyers pursuant to the Contract to Sell. A formal
demand was made for full and immediate payment of the amount of P16,994.73, representing installments
which, Antipolo Realty alleged, had accrued during the period while the improvements were being
completed i.e., between September 1972 and October 1976.
Yuson refused to pay the September 1972 - October 1976 monthly installments but agreed to pay the post
October 1976 installments. Antipolo Realty responded by rescinding the Contract to Sell, and claiming the
forfeiture of all installment payments previously made by Mr. Yuson. Yuson brought his dispute with
Antipolo Realty before NHA. Antipolo Realty filed a motion to dismiss, which NHA denied. After hearing, the
NHA rendered a decision on 9 March 1978 ordering the reinstatement of the Contract to Sell. A motion for
reconsideration of Antipolo Realty was also denied.
ISSUE: Whether or not the NHA in ordering the reinstatement of the Contract To Sell, acted on a matter
beyond its competence
RULING: No. The extent to which the NHA has been vested with quasi-judicial authority must be
determined by referring to the terms of Presidential Decree No. 957, known as "The Subdivision and
Condominium Buyers' Decree." 11 Section 3 of this statute provides as follows:
National Housing Authority. The National Housing Authority shall have exclusive jurisdiction to regulate
the real estate trade and business in accordance with the provisions of this decree. Presidential Decree No.
1344 (which amended Presidential Decree No, 957) clarified and spelled out the quasi-judicial dimensions
of the grant of regulatory authority to the NHA in the following quite specific terms:
In the exercise of its functions to regulate the real estate trade and business and in addition to its powers
provided for in Presidential Decree No. 957, the National Housing Authority shall have exclusive jurisdiction
to hear and decide cases of the following nature:
B.
Claims involving refund and any other claims filed by sub- division lot or condominium unit buyer
against the project owner, developer, dealer, broker or salesman; and
C.
Cases involving specific performance of contractual and statutory obligations filed by buyers of
subdivision lots or condominium units against the owner, developer, dealer, broker or salesman.
There is, in any case, no question that under Presidential Decree No. 957, the NHA was legally empowered
to determine and protect the rights of contracting parties under the law administered by it and under the
respective agreements, as well as to ensure that their obligations thereunder are faithfully performed.
Having failed to comply with its contractual obligation to complete certain specified improvements in the
subdivision within the specified period of two years from the date of the execution of the Contract to Sell,
petitioner was not entitled to exercise its options under Clause 7 of the Contract. Hence, petitioner could
neither rescind the Contract to Sell nor treat the installment payments made by the private respondent as
forfeited in its favor. The NHA was therefore correct in holding that private respondent's prior installment
payments could not be forfeited in favor of petitioner.

There is no question that a statute may vest exclusive original jurisdiction in an administrative agency over
certain disputes and controversies falling within the agency's special expertise. The very definition of an
administrative agency includes its being vested with quasi-judicial powers. Under the "sense-making and
expeditious doctrine of primary jurisdiction . . . the courts cannot or will not determine a controversy
involving a question which is within the jurisdiction of an administrative tribunal where the question
demands the exercise of sound administrative discretion requiring the special knowledge, experience, and
services of the administrative tribunal to determine technical and intricate matters of fact.
RATIO: Extent of Judicial or Quasi-Judicial Powers of Administrative Agencies: Function ordinarily judicial
may be conferred. In the exercise of such powers, the agency concerned must commonly interpret and
apply contracts, determine the rights of private parties under such contracts, and award damages
whenever appropriate. 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 but may be conferred upon an administrative agency.
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