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G.R. No. L-50444

In the case of Antipolo Realty Corp. vs. National Housing Authority, the Supreme Court upheld the NHA's jurisdiction and decision to protect buyer rights under PD 957, affirming that Yuson could suspend payments due to the seller's failure to complete subdivision improvements. The NHA ruled that the seller had substantially complied with obligations, allowing for the reinstatement of the Contract to Sell and extending the payment period. The court also addressed due process concerns and the interpretation of contractual provisions regarding installment payments during the suspension period.

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8 views3 pages

G.R. No. L-50444

In the case of Antipolo Realty Corp. vs. National Housing Authority, the Supreme Court upheld the NHA's jurisdiction and decision to protect buyer rights under PD 957, affirming that Yuson could suspend payments due to the seller's failure to complete subdivision improvements. The NHA ruled that the seller had substantially complied with obligations, allowing for the reinstatement of the Contract to Sell and extending the payment period. The court also addressed due process concerns and the interpretation of contractual provisions regarding installment payments during the suspension period.

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annwincatamco
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Title

Antipolo Realty Corp. vs. National Housing Authority

Case

G.R. No. L-50444

Decision Date

Aug 31, 1987

Yuson suspended payments due to Antipolo Realty's failure to complete subdivision improvements. NHA
upheld Yuson's rights, rejecting rescission and forfeiture claims. Supreme Court affirmed NHA's
jurisdiction and ruling, protecting buyer rights under PD 957.

Facts:

Background of the Transaction

 On August 18, 1970, a Contract to Sell was executed by Antipolo Realty Corporation
whereby Jose Hernando acquired prospective and beneficial ownership over Lot No. 15,
Block IV of the Ponderosa Heights Subdivision in Antipolo, Rizal.

 On August 28, 1974, Mr. Hernando transferred his rights over the lot to private
respondent Virgilio Yuson through a Deed of Assignment and Substitution of Obligor
(Delegacion), with the consent of Antipolo Realty, whereby Mr. Yuson assumed the
vendee’s obligations under the original contract.

Contractual Provisions and Obligations

 The Contract to Sell contained Clause 17, which detailed the seller’s obligation to
complete various improvements in the subdivision (e.g., concrete curbs and gutters,
underground drainage, asphalt paved roads, independent water system, electrical
installation with concrete posts, landscaping, sidewalks, a park or amphitheatre, and 24-
hour security) within two (2) years.

 Clause 17 also provided that failure by the seller to complete these improvements would
entitle the buyer to suspend monthly installment payments without incurring penalties
or interest until the improvements were completed.

Developments and Payment Dispute

 Despite the seller’s eventual communication on October 14, 1976, indicating completion
of the improvements, Mr. Yuson only paid the arrearages up to and including August
1972. He further suspended subsequent monthly installment payments until such time
as he could verify that the improvements were, in fact, completed.

 Antipolo Realty reiterated its demand for resumption of payments, citing a National
Housing Authority (NHA) decision that declared the seller had “substantially complied”
with its commitment, and demanded full immediate payment of P16,994.73
representing installments allegedly accrued between September 1972 and October
1976.

Administrative Proceedings

 In response to the rescission of the Contract to Sell by Antipolo Realty, Mr. Yuson filed a
complaint with the NHA (Case No. 2123) on May 10, 1977.

 After a series of motions and hearings—including a Motion to Dismiss by the petitioner


and a subsequent denial of that motion—the NHA, in its March 9, 1978 decision,
reinstated the Contract to Sell with conditions:

 Antipolo Realty was to send a statement of account for installments due from November
1976 onward.

 No penalty interest was to be charged from November 1976 to the issuance of said
statement.

 A 60-day period was granted to Mr. Yuson to settle the arrears.

Judicial Challenges and Contentions

 Antipolo Realty challenged the NHA’s jurisdiction and its quasi-judicial intervention,
arguing that the matter was one for the regular courts and that due process was violated
(alleging non-service of notice and lack of opportunity to be heard).

 The petitioner also contended that under Clause 7 of the Contract to Sell, it was entitled
to cancel the contract and retain preceding installment payments, arguing that Mr.
Yuson’s default (non-payment during the suspension period) justified such action.

 Subsequent petitions for certiorari and motions for reconsideration were filed, with the
NHA standing by its decision based on the evidence presented solely by the
complainant, Mr. Yuson.

Statutory and Doctrinal Framework

 The decision references the quasi-judicial character of administrative agencies such as


the NHA, which are empowered under Presidential Decree No. 957 (The Subdivision and
Condominium Buyers’ Decree) and further clarified by Presidential Decree No. 1344.

 The statutory basis emphasizes that the NHA holds exclusive jurisdiction over disputes
involving non-forfeiture of installment payments and unsound real estate practices,
thereby legitimizing its intervention into disputes that involve technical aspects and
contractual interpretations.

 The matter of whether installment payments accrued during the suspension period was
pivotal, as the NHA’s resolution determined that such installments “did not become due
and demandable” during the period of suspension, thereby justifying an extension of the
original contract period.
Issue:

Jurisdiction of the National Housing Authority

 Whether the NHA had the legal power and jurisdiction to hear and decide on the dispute
arising from the Contract to Sell.

 Whether the quasi-judicial functions conferred by Presidential Decree No. 957 and No.
1344 allowed the NHA to interpret and enforce the contractual rights of the parties.

Validity of the NHA’s Order Restoring the Contract

 Whether the NHA’s order to reinstate the Contract to Sell, allowing for the extension of
the payment period, was within the scope of its regulatory authority.

 Whether the suspension of installment payments, as practiced by Mr. Yuson due to the
seller’s failure to complete the improvements, was justified and should prevent the
accrual of arrears.

Due Process Considerations

 Whether Antipolo Realty was denied due process, particularly in terms of notice and the
opportunity to be heard before the NHA’s scheduling and hearing of the complaint.

 Whether the administrative proceedings adhered to the requisite procedural safeguards


despite allegations of irregular service of notice.

Interpretation of Contractual and Statutory Provisions

 How the contractual provisions (notably Clauses 7 and 17 of the Contract to Sell) should
be interpreted in light of the regulatory framework established by PD No. 957.

 Whether the failure of the petitioner to develop the subdivision within the stipulated
period effectively barred it from rescinding the contract or appropriating prior
installment payments

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