By Eduardo Martinez

Copyright tribune

Article 100 of the Revised Penal Code mandates that every person criminally liable is also civilly liable. It is thus normal practice that when a criminal action is instituted, the civil aspect of the crime is tried in the same case by the same court. So when the court renders a decision, it pronounces judgment not only on the criminal liability of the accused, but his civil accountability as well. We usually hear decisions where the court metes out imprisonment to the guilty party, at the same time adjudging him monetarily liable to the aggrieved for damages the latter suffered. But do take note that this does not always happen. There may be instances when the court only has jurisdiction over the criminal aspect of the act, and the adjudication of civil liability belongs to another body. Let us take this case I will discuss, for instance. The petitioner here sold a condominium unit to a buyer. There was a dispute over the payment of the entire purchase price, leading the buyer to criminally sue the seller for violation of Presidential Decree 957. After a trial on the merits, the court found the petitioner-seller not guilty of the crime charged but adjudged her civilly liable, thereby ordering her to return the purchase price. The seller disagreed with the court, arguing that the HLURB (now HSAC) had jurisdiction over the civil aspect of the case. The court disagreed, prompting her to appeal to the Court of Appeals. She did not get the nod of the appellate court. Thus, the appeal to the highest court. In this instance, the Supreme Court decreed: “Section 3 of Presidential Decree 957, or the Subdivision and Condominium Buyers’ Protective Decree, vested upon the National Housing Authority (NHA) exclusive jurisdiction to regulate the real estate trade and business. “Presidential Decree 1344 was thereafter enacted, which expanded NHA’s jurisdiction to hear and decide cases as follows: “Section 1. 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: (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 and statutory obligations filed by buyers of subdivision lot or condominium unit against the owner, developer, dealer, broker or salesman. “Then, on 7 February 1981, Executive Order 648 transferred the regulatory and quasi-judicial functions of the NHA to the Human Settlements Regulatory Commission which, in 1986, was renamed the HLURB. Finally, on 14 February 2019, the HLURB was reconstituted as the Human Settlements Adjudication Commission (HSAC) pursuant to Republic Act 11201. “At the time of the filing of the criminal case before the RTC, it was the HLURB that had jurisdiction over cases filed by the buyer or owner of a subdivision or condominium unit based on any of the causes of action above enumerated under Section 1 of Presidential Decree No. 1344. There is no quarrel that the RTC had jurisdiction over the criminal action filed by the respondent against the petitioner for violation of Presidential Decree No. 957 because the HLURB was not specifically conferred with the power to hear and decide cases which are criminal in nature. “The issue now is on the civil liability that was adjudged on the criminal case, which, as earlier explained, was ex contractu, or one which arose from the parties’ contractual obligation. Verily, the RTC rendered the judgment on the civil liability of the parties without jurisdiction over the subject matter of the case; it pertained to the parties’ breach of contractual obligations which is under the exclusive jurisdiction of the HLURB. “Following the rule that a court without jurisdiction cannot render a valid judgment, the ruling of the RTC on the parties’ civil liability is therefore null and void for lack of jurisdiction.”The facts and redacted quoted portion of the decision are from G.R. No. 254543 (2 April 2025).