Peña Vs Government Service Insurance System, 502 SCRA 295 Case Digest (Administrative Law)

Administrative Law
Arellano University School of Law

aiza ebina/2015
Pea vs Government Service Insurance System

502 SCRA 295
Extent of Judicial or Quasi-Judicial Powers of Administrative Agencies
FACTS: Petitioner acquired three subdivision lots from Queens Row Subdivision, Inc., through its President
Isabel Arrieta, by virtue of a Deed of Absolute Sale, with a right to repurchase the same within two months,
for the sum of P126,000.00 plus interest. However, petitioner alleged that Queens Row Subdivision, Inc.
failed to repurchase said lots and refused to deliver the corresponding titles of the said subdivision lots
because the same were mortgaged to GSIS without the written approval of the Housing and Land Use
Regulatory Board as required by Presidential Decree No. 957, otherwise known as "The Subdivision and
Condominium Buyers Protective Decree."
Petitioner filed a Complaint for Specific Performance, Annulment of Mortgage, and Damages before the
HLURB Regional Office against Queens Row Subdivision, Inc., asking for the cancellation of the mortgage
to respondent and the consolidation of ownership to her, alleging that the mortgage of the subject lots to
the respondent was null and void because it had no written approval of the HLURB as required under
Presidential Decree No. 957.
HLURB rendered a Decision in favor of petitioner. Respondent filed a Notice of Appeal from the aforementioned Decision. HLURB issued an Order denying the said appeal.
Petitioner then claimed that for failure of respondent to file the proper mode of appeal within the
reglementary period before the HLURB, its Decision already became final and executory.
Respondent filed a Motion to Declare Judgment Null and Void Ab Initio before the Board of Commissioners
of the HLURB, claiming that the Regional Office of HLURB had no jurisdiction to resolve the Complaint for it
involved title to, possession of, or interest in real estate, the jurisdiction of which belonged to the Regional
Trial Court. Respondent also contended that the mortgage transaction was exempt from the provisions of
Presidential Decree No. 957 because it was entered into prior to the effectivity of the said decree. The
HLURB Board of Commissioners issued an Order denying the said Motion for lack of merit.
Dissatisfied, respondent sought reconsideration of the aforesaid Order. Still, the HLURB Board of
Commissioners denied the Motion for Reconsideration of the respondent because the Decision of HLURB
has already become final and executory. Once again aggrieved, respondent appealed the foregoing Order
of the HLURB Board of Commissioners to the Office of the President. The Office of the President ruled in
favor of the respondent declaring that the mortgage of the subject lots to GSIS is valid and subsisting.
Petitioner filed a Petition for Review before the Court of Appeals alleging that the Office of the President
committed grave and serious errors, among others, in not holding that the Decision of the HLURB Regional
Office had become final and executory; and in not holding that the HLURB Board of Commissioners as well
as the Office of the President had no jurisdiction or authority to revive, review, change, or alter the said
final and executory Decision.
ISSUE: Whether or not the HLURB had no jurisdiction or authority to revive, review, change, or alter the
said final and executory Decision
RULING: No. The decision of HLURB Regional Office was already final and executory, no court, not even
the highest court of the land, can revive, review, change or alter the same. It is already well settled in our
jurisdiction that the decisions and orders of administrative agencies rendered pursuant to their quasijudicial authority, have, upon their finality, the force and binding effect of a final judgment within the
purview of the doctrine of res judicata. The rule of res judicata, which forbids the reopening of a matter
once judicially determined by competent authority, applies as well to the judicial and quasi-judicial acts of
public, executive, or administrative officers and boards acting within their jurisdiction.
The Motion to Declare Judgment Null and Void Ab Initio filed by respondent after so many months from the
finality of the Decision it seeks to be declared null and void, can no longer be entertained by the HLURB
Board of Commissioners. The same was just an attempt to reinstate an appeal that had already been lost.
Even granting arguendo that the said Motion was proper, still, the allegation therein of the respondent that
the HLURB Regional Office had no jurisdiction over the case because it involved title to, possession of, or
interest in real estate, the jurisdiction of which supposedly belonged to the Regional Trial Court, was not
sufficient to warrant the declaration of the Decision of the HLURB as null and void. Such ground relied upon
by the respondent is untenable because the jurisdiction involving unsound real estate practices and other
matters in connection thereto belongs to HLURB.
When an administrative agency or body is conferred quasi-judicial functions, all controversies relating to
the subject matter pertaining to its specialization are deemed to be included within the jurisdiction of said
administrative agency or body. Split jurisdiction is not favored. Therefore, the Complaint for Specific
Performance, Annulment of Mortgage, and Damages filed by petitioner against respondent, though
involving title to, possession of, or interest in real estate, was well within the jurisdiction of the HLURB for it
involves a claim against the subdivision developer, Queens Row Subdivision, Inc., as well as respondent.
RATIO: When an administrative agency or body is conferred quasi-judicial functions, all controversies
relating to the subject matter pertaining to its specialization are deemed to be included within the
jurisdiction of said administrative agency or body. Split jurisdiction is not favored.
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Administrative Law

Arellano University School of Law

Pea vs Government Service Insurance System

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