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CADUNGOG V. JUNG [ G.R. No. 254543, April 02, 2025 ]

CADUNGOG V. JUNG [ G.R. No. 254543, April 02, 2025 ]
Posted by:PJP
Interactive Case Summary: Cadungog v. Sung Ha Jung

SUPREME COURT - THIRD DIVISION

[ G.R. No. 254543, April 02, 2025 ]

VIVIEN M. CADUNGOG, PETITIONER, VS. SUNG HA JUNG, RESPONDENT.

Case Summary: Annulment of Judgment & Jurisdiction

  • This case tackles a crucial issue of jurisdiction. A developer was acquitted in a criminal case but was still ordered by the Regional Trial Court (RTC) to pay civil damages arising from a contract dispute. The developer later sought to annul this civil award, arguing the RTC had no jurisdiction over it. The Supreme Court agreed, ruling that the civil liability arose from a contract (*ex contractu*), not the crime (*ex delicto*), and thus fell under the exclusive jurisdiction of the Housing and Land Use Regulatory Board (HLURB). The Court declared the RTC's judgment on the civil liability null and void.
  • The Contract: Vivien Cadungog, a condominium developer, entered into a Contract to Sell with Sung Ha Jung for a unit in Sophela Tower for PHP 3,500,000.00.
  • The Dispute: A dispute arose over the final payment. Jung claimed to have paid in full, while Cadungog insisted there was an unpaid balance of PHP 258,950.00. Due to this, Cadungog refused to deliver the unit's title.
  • Criminal Case: Jung filed a criminal complaint against Cadungog for violating P.D. 957 (failure to deliver title after full payment).
  • RTC Ruling: The RTC acquitted Cadungog of the criminal charge, finding that the purchase price was not fully paid. However, it still ruled on the civil liability, ordering the parties to either complete the sale (Jung pays the balance, Cadungog delivers the unit) or rescind it (Cadungog refunds the amount paid).
  • Annulment of Judgment: Cadungog later filed a Petition for Annulment of Judgment with the CA, arguing the RTC had no jurisdiction over the civil aspect of the case, which she claimed belonged exclusively to the HLURB.
  • CA Ruling: The CA dismissed the petition, stating that the civil action was impliedly instituted with the criminal case and that annulment of judgment is not a proper remedy.
  • Did the RTC have jurisdiction to rule on the civil liability arising from the Contract to Sell?
  • Was a Petition for Annulment of Judgment the proper remedy to challenge the RTC's ruling on civil liability?

The Supreme Court GRANTED the petition and declared the RTC's judgment on civil liability NULL and VOID.

  • RTC Lacked Jurisdiction: The civil liability imposed by the RTC was based on the contract (*ex contractu*), not the crime (*ex delicto*). Under P.D. 1344, claims for refund or specific performance between a condominium buyer and a developer fall under the exclusive jurisdiction of the HLURB (now HSAC). Therefore, the RTC had no jurisdiction to rule on this specific civil aspect.
  • Annulment of Judgment was Proper: A Petition for Annulment of Judgment under Rule 47 is a proper remedy when a judgment is void for lack of jurisdiction. Because the RTC's civil ruling was void, it could never become final and executory. The rule that this remedy is unavailable if other remedies (like an appeal) were lost through the petitioner's fault does not apply when the ground is lack of jurisdiction.
  • Jurisdiction over Subject Matter: Jurisdiction is conferred by law. A court's judgment on a matter outside its jurisdiction is null and void.
  • HLURB/HSAC Jurisdiction (P.D. 1344): The HLURB (now HSAC) has exclusive jurisdiction over claims for refund and specific performance of contractual obligations filed by condominium buyers against developers.
  • Annulment of Judgment (Rule 47): This is an extraordinary remedy to nullify a final judgment. When grounded on lack of jurisdiction, it can be filed at any time (unless barred by laches) and does not require showing that other remedies were unavailable through no fault of the petitioner.