Luzon Development Bank vs Association of LDB Employees 249

SCRA 162
From a submission agreement of the LDB and the Association of Luzon Development
Bank Employees (ALDBE) arose an arbitration case to resolve the following issue:
Whether or not the company has violated the CBA provision and the MOA on
promotion.
At a conference, the parties agreed on the submission of their respective Position
Papers. Atty. Garcia, in her capacity as Voluntary Arbitrator, received ALDBEs Position
Paper ; LDB, on the other hand, failed to submit its Position Paper despite a letter from
the Voluntary Arbitrator reminding them to do so. As of May 23, 1995 no Position Paper
had been filed by LDB.
Without LDBs Position Paper, the Voluntary Arbitrator rendered a decision disposing as
follows:
WHEREFORE, finding is hereby made that the Bank has not adhered to the CBA
provision nor the MOA on promotion.
Hence, this petition for certiorari and prohibition seeking to set aside the decision of the
Voluntary Arbitrator and to prohibit her from enforcing the same.
ISSUE: WON a voluntary arbiters decision is appealable to the CA and not the SC
HELD: YES, the jurisdiction conferred by law on a voluntary arbitrator or a
panel of such arbitrators is quite limited compared to the original jurisdiction
of the labor arbiter and the appellate jurisdiction of the NLRC for that matter.
The (d)ecision, awards, or orders of the Labor Arbiter are final and
executory unless appealed to the Commission Hence, while there is an
express mode of appeal from the decision of a labor arbiter, Republic Act No.
6715 is silent with respect to an appeal from the decision of a voluntary
arbitrator.
Yet, past practice shows that a decision or award of a voluntary arbitrator is,
more often than not, elevated to the SC itself on a petition for certiorari, in
effect equating the voluntary arbitrator with the NLRC or the CA. In the view
of the Court, this is illogical and imposes an unnecessary burden upon it.

IRON AND STEEL AUTHORITY, petitioner, vs.THE COURT OF APPEALS

and MARIA CRISTINA FERTILIZER CORPORATION, respondents.
Facts: The NSC wanted to get land for expansion in Iligan City that was
occupied by chemical fertilizer plants of MCFC. They entered into
negotiations pursuant to LOI No. 1277. These negotiations failed. Also
pursuant to the LOI, the ISA (which was created by PD No. 272) intervened
and filed expropriation case against MCFC for the land in the RTC in Iligan.
While the case was on going, the statutory existence of ISA ceased (PD 272
and EO 555 only extended the term of ISA until 1979). MCFC filed for
dismissal because there was no longer a plaintiff since ISA was inexistent
and RTC granted it. ISA appealed and RTC said that the Government couldnt
replace them and so the case should be dismissed. RTC also said that since
the ISA was expropriating for NSA it wasnt for public benefit and not the
right use of eminent domain. ISA appealed to CA and CA said that the case
was dismissed but the government could file a case for eminent domain
because it was for public benefit seeing as the NSA was a government
subsidiary. Appeal went up to the SC.
Issue: Whether or not the Government could replace ISA in the judicial
proceedings
Held: Yes, Pursuant to Rules of Court, the parties of a case can either be
natural or juridical persons. The ISA is a juridical person as it was given
power to enter into contracts and acquire land for the iron and steel industry
pursuant to PD 272. Now we have to make a distinction between certain
kinds of government agencies those incorporated and non-incorporated.
Incorporated agencies have a separate identity than that of the government,
so when theres a case against them, the Government cannot interfere. BUT
for non-incorporated agencies like the ISA, they are not distinct from the
Government, they are only given certain functions. In this case, the ISA is
supposed to be able to help the Government acquire shiz to aid in the steel
industry. Since non-incorporated agencies are not separate from the
Government, then the Government can totally replace them if they cease to
exist in a pending case. The SC quoted the EB Marcha case that basically
said the government can totally step in for its agents and that to have to
restart the trial would be a multiplication of suits and a waste of time.
Furthermore, the SC affirmed partially what the CA said when it held that the
RTC was premature to dismiss the whole thing because the expropriation
case hadnt actually been heard on its merits. LASTLY, the power of eminent
domain is lodged in the legislative, the 1917 and 1987 Administrative Code
gave this to the President also. So Decision of RTC REVERSED and
REMANDED

Solid Homes, Inc. vs. Payawal, 177 SCRA 72, 79 (1989)

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 Authority has the jurisdiction to decide the
case.
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 real estate business practices;
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 contractual statutory obligations
filed by buyers of subdivision lot or condominium unit against the owner,
developer, dealer, broker or salesman.
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 the
problems thereof with more expertise and dispatch than can be expected
from the legislature or the courts of justice. This is the reason for the

increasing vesture of quasi-legislative and quasi-judicial powers in what is

now not unreasonably called the fourth department of the government.

CGA vs Ignacio G.R. No. 164789

The extent to which an administrative entity may exercise judicial or quasijudicial 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.
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 mutually agreed to amend the Contract to Sell to extend the payment
period from three to five years. According to CGA, it religiously paid the
monthly installments until its administrative pastor discovered that the title
covering the subject property was actually part of two consolidated lots (Lots
2-F and 2-G Bsd-04-000829 [OLT]) that the respondents had acquired from
Nicanor Adriano (Adriano) and Ceferino Sison (Sison), respectively. Adriano
and Sison were former tenant-beneficiaries of Purificacion S. Imperial
(Imperial) whose subject property had been placed under Presidential Decree
(PD) No. 27s Operation Land Transfer. According to CGA, Imperial applied
for the retention of five hectares of her land under Republic Act No. 6657,
which the Department of Agrarian Reform (DAR) granted. The DAR Order
authorized Imperial to retain the farm lots previously awarded to the tenantbeneficiaries, including Lot 2-F previously awarded to Adriano, and Lot 2-G
Bsd-04-000829 awarded to Sison. Understandably aggrieved after
discovering these circumstances, CGA filed a complaint against the
respondents before the RTC. CGA claimed that the respondents fraudulently
concealed the fact that the subject property was part of a property under
litigation; thus, the Contract to Sell was a rescissible contract under Article
1381 of the Civil Code. CGA asked the trial court to rescind the contract;
order the respondents to return the amounts already paid; and award actual,
moral and exemplary damages, attorneys fees and litigation expenses.
Instead of filing an answer, the respondents filed a motion to dismiss
asserting that the RTC had no jurisdiction over the case. The respondents
claimed that the case falls within the exclusive jurisdiction of the HLURB
since it involved the sale of a subdivision lot. CGA opposed the motion to
dismiss, claiming that the action is for rescission of contract, not specific

performance, and is not among the actions within the exclusive jurisdiction
of the HLURB.
ISSUE: Which of the two the regular court or the HLURB has exclusive
jurisdiction over CGAs action for rescission and damages.
HELD: HLURB has exclusive jurisdiction over CGAs action for rescission and
damages.
Rationale for HLURBs extensive quasi-judicial powers The surge in the real
estate business in the country brought with it an increasing number of cases
between subdivision owners/developers and lot buyers on the issue of the
extent of the HLURBs exclusive jurisdiction. The courts have consistently
ruled that the HLURB has exclusive jurisdiction over complaints arising from
contracts between the subdivision developer and the lot buyer or those
aimed at compelling the subdivision developer to comply with its contractual
and statutory obligations to make the subdivision a better place to live in.
Generally, the extent to which an administrative agency may exercise its
powers depends largely, if not 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. Civil Service Commission

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 the unposted withdrawal of P60,000 from
the savings accounts of the Tiu. 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: 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
Commission. In any event, there was an earlier statement of the facts and
the law involved in the decision rendered by the MSPB dated February 28,
1990, which affirmed DBP's decision to dismiss the petitioner. In both
decisions, the facts and the law on which they were based were clearly and
distinctly stated.

Lianga Bay Logging, Co., Inc. v. Enage, G.R. No. L-30637, July 16,
1987
Facts: 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.
Issue: WON respondent court has jurisdiction over the administrative case
Held: Respondent Judge erred in taking cognizance of the complaint filed by
respondent Ago, asking for the determination anew of the correct boundary
line of its licensed timber area, for the same issue had already been
determined by the Director of Forestry, the Secretary of Agriculture and
Natural Resources and the Office of the President, administrative officials
under 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.